At Source, we’ve always kept your data safe and treated it with the respect your privacy deserves. As a trusted recruitment agency, we understand that private information should stay just that, private. But with the new laws coming into effect on 25th May, we’ve reviewed our privacy policies to ensure they are the best they can be, and made some changes.
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:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date;
- Kept only as long as necessary for the purposes we have told you about; and
- Kept securely.
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:
- The information you have provided to us in your curriculum vitae and, where applicable, your covering letter, emails with us and/or on our online registration form.
- The information you have provided on our candidate registration form, including (but not limited to) your name, address, telephone number, personal email address, date of birth, and details about your previous employment history.
- Any relevant information you provide to us during a registration meeting, whether on the telephone or in person.
- Any due diligence information provided to us in order to engage you as an employee of one of our Clients or on board you as a Temporary Worker (including documentation relevant to 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). We may also collect, store and use the following "special categories" of more sensitive personal information:
- Information about your health (if it’s relevant to the recruitment process), including any medical condition, health and sickness records.
- Information about any disabilities you may have and reasonable adjustments you may require.
- Information about criminal convictions and offences (if relevant to the recruitment process).
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:
- 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 and reason for leaving.
- Publicly accessible sources such as internet, social networks, world-check and/or commercial registers.
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:
- To assess your skills, qualifications, and suitability for a particular role or more generally for a particular type of work or Company.
- To carry out background and reference checks, where applicable.
- To communicate with you about the recruitment process.
- To keep records related to our recruitment and hiring processes.
- To comply with legal or regulatory requirements.
- To where you have opted in, 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.
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:
- 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 need to be made.
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:
- We are legally required by certain regulatory bodies to carry out criminal record check for those carrying out roles or work regulated by those entities;
- 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 and so we would like to ask you to seek a basic disclosure of your criminal record history.
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:
- Request access to your personal information (commonly known as a "data Subject Access Request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
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.
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