Who we are and the purpose of this document
This privacy notice is issued by Source Recruitment Specialists Limited (Source). We understand that your privacy is important. We therefore respect your right to privacy and will process your personal data in accordance with the Data Protection (Bailiwick of Guernsey) Law 2017 (DP Law) and any other applicable data protection laws.
Under the DP Law, Source is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. This privacy notice is applicable to any person who registers to receive notifications about new job vacancies and/or who registers with us as a candidate and/or who is applying for work with us (whether as an employee, temporary worker or contractor). 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 a responsible organisation, it is our intention to at all times comply with applicable data protection law and principles, which means that your data will be:
What data do we hold 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:
Please note that these lists are not exhaustive and that Source may also collect and process personal data to the extent that it is useful or necessary for the provision of our services. In connection with any person who registers to receive notifications about new job vacancies, we will collect your name, and email address and ask you to select the sectors you are interested in.
How do we collect your personal data?
We collect personal information about candidates in a number of different ways and from the following sources:
We may also receive personal data about you from third parties as part of the service that we provide or in connection with legal requirements that are applicable to us and our business.
How we will use the personal data you provide to us?
The majority of the personal data that we collect about you is necessary for the performance of a contract to which you are a party, or to comply with a request by you prior to entering into a contract with either Source or one of our clients. Source also processes your personal data in order to comply with our legal and regulatory obligations.
Our business concerns recruitment and involves the placement of individual candidates with companies/businesses within the Bailiwick of Guernsey mainly but occasionally in other jurisdictions. We will therefore hold and process your personal data as part of any activity in the pursuit of our legitimate business interests as a registered recruitment agency.
More specifically, we will collect and process your personal data for the following purposes:
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.
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. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive personal data
We will use your particularly sensitive personal information in the following ways:
Information about criminal convictions
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:
Automated decision making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Who do we share your personal data with?
We may share, disclose or transfer your personal data with third party service providers who support our core business services.
Except as described in this statement, Source will not transfer or sell your personal data to any third party unless you have specifically consented to this. We will only share your personal information for the purposes of processing your application, including but not limited to identifying and securing placement opportunities with our clients, with client companies who have registered positions with Source and in which you have registered an interest and have provided your permission.
All our third-party service providers 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 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.
In the event of a sale or potential sale of Source, or where it is 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.
In the unlikely event that a transfer of data is necessary outside of Guernsey and/or the EEA to a country that does not have an adequate level of protection for your personal data, Source will ensure that additional safeguards will be put in place to ensure the protection of your personal data.
How do we keep your personal data secure?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from Rick Martin, Joint Managing Director.
We have put in place procedures to deal with any suspected data security breach and will notify you of a suspected breach where we are legally 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 from Rick Martin, Joint Managing Director.
What are my rights?
Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact Julia Martin, Joint Managing Director, in writing.
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 Julia Martin, Joint Managing Director. 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.
This policy was last updated on 10 May 2018.