HT Recruitment Limited
1.2. All your Personal Data shall be held and used in accordance with Data Protection Laws (which include:
1.4. The Company ensures on an ongoing basis that all of its suppliers and third parties operate in compliance with GDPR.
1.5 For any Data Protection or GDPR-related enquiries in connection with our business, please contact us: By email: email@example.com or By mail: HT Recruitment Limited 120 Bunns Lane, London, NW7 2AS, UK
2. Data Controller
2.1. The Company is the controller and responsible for your personally identifiable information (Personal Data) as listed in clause 3 below.
3. Information we collect
3.1. The Company aims to collect the minimum data it needs to perform its role. The information we may collect on our candidates includes: a)
3.2. 3.2. The information we may collect on our clients includes:
3.3. We use automated technologies and interactions to collect data from and about you, users of the Site. With regard to each of your visits to our Site we may automatically collect the following information (Automated Data):
4. We collect technical data through analytics providers, advertising networks and search information providers. A list of these third parties can be provided to you on request. Where we collect information from
4.1. You may give us information about you:
4.2. We may receive information about you from third party sources including employment related search engines and platforms for job listings from which we may gather your information and make contact with job opportunities with your consent. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site.
4.3. We work closely with third parties (including, for example, business partners, sub-contractors in technical and payment services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. A list of these third parties can be provided to you on request.
5. Disclosure of your information
5.1. We will not share your Personal Data unless we have a legal basis for doing so as set out in clause 6. Third parties who we may share your Personal Data with include:
5.2. We may disclose your Personal Data to third parties if:
6. The legal basis for processing your Personal Data
6.1. The Company will only process Personal Data where there is a lawful basis as per Data Protection Laws. This lawful basis shall be one or more of the following:
6.2. Legitimate interests are a flexible basis upon which the law permits the processing of an individual's Personal Data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Manager. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest.
6.3. We will use Automated Data to:
6.4. We will use data to perform a number of tasks including:
6.5. In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee's entitlement to work in the UK.
6.6. In other cases, the organisation has a legitimate interest in processing Personal Data before, during and after the end of the employment relationship. Processing employee data allows the organisation to:
7. Where We Store your Personal Data
7.2. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7.4. As a result of increased risk posed by cyber fraud please do not send any funds until you have received confirmation from your relevant contact and are certain as to the correct account details. Unfortunately, we do have to warn you that we cannot accept responsibility if you transfer money into an incorrect account.
8. Your Legal Rights
8.1. When reading this notice, it might be helpful to understand that your rights arising under Data Protection Laws include:
9. Data Security
9.1. We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
9.2. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Data Accuracy
10.1. The Company shall ensure that all Personal Data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of Personal Data at the request of a data subject, as set out in clause 9, above.
10.2. The accuracy of Personal Data shall be checked when it is collected and at regular intervals thereafter. If any Personal Data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
11. Data Retention
11.1. The Company will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
11.2. Candidate’s records including application form/CV, ID checks, terms of engagement, details of assignments, opt notices and interview notes for unsuccessful candidates will be held for a minimum of 12 months from the last date of supply or introduction to any client.
11.3. Where we have limited contact with a candidate following an unsuccessful interview and placement process it will be held for a maximum of three years from the last date of contact with you.
11.4. All categories of Personal Data that are held by us because they are essential for the performance of a contract, will be held for a period of six years, as determined by reference to the Limitations Act 1980, for the purposes of exercising or defending legal claims.
11.5. Further information on our how long we retain information is attached as Annex A to this policy.
12.1. We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.
12.2. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.
12.3. You will receive marketing communications from us if you choose to opt-in via our Website or other similar electronic or paper notices concerning the same.
13.1. Similar to other commercial websites, our Site uses a technology called "cookies" and web server logs to collect information about how our Site is used. Cookies are small text files that are placed on your computer's hard drive through your web browser when you visit any web site. They are widely used to make web sites work, or work more efficiently, as well as to provide information to the owners of the site.
13.2. Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our Site. The cookies we use may last for a single visit to our Site (they are deleted from your computer when you close your browser), or may remain on your computer until you delete them or until a defined period of time has passed.
14. Opt Out
14.1. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at firstname.lastname@example.org or email@example.com.
14.2. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us.
15. Access to information
15.1. Data Protection Laws gives you the right to access information held about you. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
17. Your Duty to Provide us With Accurate Data It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
18. If you fail to provide us with Personal Data
The information about you that we have collected for the performance of our contracts is required in order for us to successfully fulfil our obligations to you. If you choose not to provide the Personal Data requested, we will not be able to enter into a contract with you to provide the benefits we offer. If we are already processing your Personal Data under a contract, you must end our contractual relationship (as/where permitted) in order to exercise some of your rights.
If you are unhappy about our use of your Information, you can contact us at the address or email address above. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods. Telephone: 0303 123 11113 Website: https://ico.org.uk/concerns/ Post: Information Commissioner's Office Wycliffe House Water Lane Wilmslow, Cheshire SK9 5AF
ANNEX A Data Retention Policy
Document Type Length Records Held
Candidate records including application form/CV, ID checks terms of engagement (see below also, details of assignments, opt notices and interview notes for unsuccessful candidates Minimum 1 year from the last date of supply or introduction to any client (Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Conduct Regulations)) Hirer records including client details, terms of business (see below also), assignment/ vacancy details Minimum 1 year from the last date of supply or introduction to any client (Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Conduct Regulations))
Terms of Engagement with temporary worker and Terms of Business with clients 6 years in order to deal with any civil action in the form of contractual claim (Limitation Act 1980).Although this is only 5 years in Scotland we maintain 6 years Staff records including CV, ID, bank details, reference information and other personnel information (e.g. absence & disciplinary records) 2 years from employee termination date
Working time records: • 48 hour opt out notice • Annual leave records 2 years from the time they were created
Annual appraisal/ assessment records 5 years (Under the DPA no specific period is detailed so records should only be kept as long as necessary) References 2 years following the introduction to a client OR 2 years after engagement has ended, whichever is the later (Under the DPA records are only to be kept as long as necessary however the Conduct Regulations require references to be kept for 1 year) Records held relating to right to work in the UK 2 years after employment or engagement has ended Criminal record checks 6 months following the introduction to a client OR 2 years after engagement has ended, whichever is later National Minimum Wage Documentation:
Total pay by the worker and the hours worked by the worker • Overtime/ shift premium; • Any deduction or payment of accommodation; • Any absences e.g. rest breaks, sick leave, holiday; • Any travel or training during working hours and its length; • Total number of hours in pay reference period – this sets the averaging period to calculate whether a worker has been paid • NMW e.g. workers paid weekly have a pay reference period of one week 7 years after the end of the pay reference period following the one that the records cover (National Minimum Wage Act 1998)
(We must keep them for 5 years in Scotland, and 6 years for the rest of the UK, in order to show that we have paid at least national minimum wage rates if a civil claim is brought against Sickness records – statutory sick pay 7 years Statutory maternity, paternity, adoption pay 7 years from the end of the tax year to which it relates Pension auto-enrolment 7 years (including for opt out notices)
Company Financial Records
Document Type VAT 7 years Company Accounts 7 years Payroll Information 7 years from the end of the year
If you are a contractor our teams are on hand to provide assistance throughout your contract. firstname.lastname@example.org