Privacy notice, January 2018 Introduction Source-Code Recruitment Ltd. is committed to protecting and respecting your privacy. Under data protection laws, we are the data controller in relation to personal information we collect about you for the purposes of recruitment with us. This means we are responsible for deciding what information to collect about you and how it is used. This notice explains what personal information we collect about you, how and why we use it, who we disclose it to, and how we protect it. What are the data protection laws? The Data Protection Act 1998 contains most of the rules about how personal information should be collected and processed. It has been replaced on 25 May 2018 by the EU General Data Protection Regulation (GDPR). Other rules exist which govern things like email direct marketing. This privacy notice takes account of all of the rules, including GDPR. CONTENTS 1. What personal information do we collect, and why? 2. Using your personal information 3. What is the lawful basis for processing? 4. Sharing your personal information with others 5. How we protect your personal information 6. How long we keep your personal information 7. Your rights 8. Contacting us 9. Contacting the Information Commissioner’s 1. What personal information do we collect? What is personal information? Personal information broadly means information about a living individual who can be identified from that information directly, or indirectly (for example if it is combined with other available information). We will collect the following information about you in connection with your employment, membership or engagement with the firm: name, email address and telephone number residency, nationality and work permit status information relating to your application to the firm, such as interview notes and test results, information contained within your CV, We will always try to keep the amount of personal information we collect to the minimum needed. 2. Using your personal information We use your personal information for the following purposes: In connection with your application to the firm. We hold your personal information because we need it to process your application for the role you have applied for, as well as be able to report and monitor the progress of candidates through each stage of recruitment. We may ask you to undertake a form of profiling called psychometric testing as part of your application and we will provide more information about this if it applies to you, however we do not use any form of automated decision making as part of the selection process. In connection with our management responsibilities. Our management responsibilities are those necessary for the effective functioning of the business and to support our decision making process in relation to our recruitment activities. In connection with our statutory and compliance responsibilities. We will process your personal information to meet our obligations under equal opportunity and other employment legislation. 3. What is the lawful basis for processing? In general, we do not require your consent to process your personal information because: we need your personal information for our legitimate interests, which are to consider your application to the firm and meet and manage our responsibilities described in section 2, or we need it to comply with the law. However you do have the right to object to how we process your personal information, or ask us to restrict processing. Some of the information we collect is known as “sensitive personal data” or “special categories of data” where the rules about how we process it are stricter. We will only collect and use this information with your explicit consent (for example if you provide voluntary diversity information) or if we are permitted to do so by law (for example under exemptions contained in the data protection laws). You are entitled to withdraw your consent at any time by Contacting us. If you withdraw your consent or object to our processing you can ask us to restrict the processing of your personal information, this won’t affect the lawfulness of the processing we’ve already carried out. Please see the Your rights section for more details. 4. Sharing your personal information with others We will only every share your information with a company for whom you have provided us your consent to have your information shared with for the purposes of applying for a new job. 5. How we protect your personal information Our legal obligations and commitment to you: We will ensure an appropriate level of security to protect your personal information, including protection against unauthorised disclosure or unlawful processing and against accidental or intentional loss, destruction or damage. We regularly review all our systems, policies and technologies to ensure that these continue to work effectively to protect your personal information. 6. How long we keep your personal information If you have made an application to us/our clients, we will keep personal information in connection with your application for 3 years, then delete it. We may in certain circumstances need to hold your personal information for longer, for example in relation to a legal dispute or because of regulatory requirements. When we contact you for the first time with a job offer we believe is suitable to you, we will keep your data for 30 days. If you do not respond to us within that period we will delete your data. 7. Your rights You have a number of rights under data protection laws. These are: to request access to your personal information, to request that your personal information is corrected if it is out of date, inaccurate or incomplete, to request that your personal information is deleted or removed from our records and systems, to make a complaint to the Information Commissioner’s Office. You also have the right: to withdraw your consent to the processing of your personal information (where we need your consent to process your personal information), to object to or restrict the processing of your personal information (where we don’t need your consent to process your personal information), to obtain an electronic file of your personal information or have it transferred to another data controller in limited circumstances. How do I exercise my rights? If you would like to make a request to access or correct your personal information, or to exercise any of your other rights, you can contact us at any time using the details set out in the Contacting Us section. We will respond to any request received from you within one month from the day we receive your request. Where it is not possible to meet your request within one month, we will still respond to you within that time to let you know. Please note that some of your rights are restricted, and will apply only in certain circumstances. For example, we may refuse to delete your personal information whilst we need it for a valid purpose, including to defend any potential legal claims. We will set out in our response our reasons if we are unable to meet your request. 8. Contacting Us If you have any queries about how we use your personal information please contact the recruitment team in the first instance by email at support@source-code.com 9. Changes to this privacy notice This privacy notice is current as of January 2018. We may make changes from time to time and you should regularly check for updates.
