Renew Recruitment Consultancy Limited – Privacy Policy (GDPR)
Introduction
Renew Recruitment Consultancy Limited take your privacy very seriously. We are dedicated to operating in a transparent and compliant manner, and upholding and safeguarding your privacy rights.
This Policy provides you with information on how Renew Recruitment Consultancy Limited work with personal data. In it we describe how we collect, use and process your personal data, and our legal bases for doing so. We give details of how you can gain access to and interact with that data, and describe your rights, as well as how we ensure those rights are upheld.
This Privacy Policy applies to any and all personal data that we work with from external Data Subjects, including Candidates, Clients, Suppliers, Website Users and anyone else who we may contact. For reference, if you are Staff of Renew Recruitment Consultancy Limited, you should refer to the Staff Privacy Policy, which is available from your line manager.
From time to time, we may amend this Privacy Policy, and all updates will be posted here. We recommend that you check this page regularly to keep up-to-date.
For definitions of words used in this Privacy Policy, please see the Glossary at the end.
General information about your data:
Who do we collect data from?
- How do we collect data?
- What data do we collect?
- How do we use your data?
- Who do we share your data with?
Candidates: We’re a recruitment agency, and in order to provide you with employment or contract opportunities that are well-matched, we need to retain and process certain information. We only request information that will help us to provide you with well-matched opportunities. The types of information we require are regularly found on CVs, and, where appropriate, may include Special Category data (for example, where we need to ensure security clearance will be possible). We may also request more general information about your career aspirations, motivations and personal situation in order to help find you the best vacancy possible.
We collect this data either directly from you, or from third parties such as online CV Databases where you have requested that your data be made available to view by companies such as ours. Third parties also include people who refer us to you.
We use your data to help find you suitable career opportunities and at times, offer you further advice on how to approach your career. The more information you provide to us, the better service we can provide to you, as we can better match you to specific Clients and vacancies that match your personal requirements.
As part of this service, we may also use your personal data to send mass mail merges that we believe are relevant to the specific skills that you have. These mail merges do not take all of your motivations into account, but we believe are worthwhile informing people of (e.g. to inform a large number of our Candidates of a Power Generation vacancy that would be suitable for someone who wants to take the next career step up from Service Engineer)
Who do we share your data with?
As a recruitment agency, our aim is to match you with suitable career opportunities. As such we will share your data with third parties in the pursuit of reaching that goal. Primarily this will be our Clients, who we believe will be interested in considering you for a job opportunity, but it may also include other third parties where we believe it will help us to provide our service to you (e.g. an organisation that can help you set up as a limited company contractor).
Clients: To offer our recruitment services, we will need to store information about your organisation, as well as individuals in your organisation. This includes phone numbers and email addresses, as well as organisational structures and profiles.
This information is used to ensure we can provide our service to you, such as sending Candidate applications, advising on recruitment processes, providing updates on specific Candidates and more. We also use this information to provide accurate and detailed information on your company to Candidates, ensuring that if they choose to proceed with an application, they already have a good understanding of what the company is all about.
We collect this data either directly from you, from online sources (e.g. your website, or social networking platforms), or from third parties (such as Candidates or your employees).
This data will be shared in the pursuit of delivering our service to you. It will primarily be shared with Candidates to promote your company, or provide details of interview requests, and the people who will be conducting the interviews. It may also be shared with other third parties where we believe it will help us provide our service to you (e.g. recruitment software providers).
Suppliers: To purchase from you, or use your services, we will need to store information about your organisation, as well as individuals in your organisation.
We collect your data when you contact us to supply, via external media, or through our general day-to-day working with you.
This information is used to ensure we can fulfil our contractual and legal obligations, as well as ensuring that your services/product continue to run smoothly and benefit our organisation.
We share your information with both individuals and companies to whom we provide services. The primary reason will be where, to deliver our service effectively, it is necessary that they are able to contact you. For completeness, this may include instances where a supply issue has arisen, it has affected a third party, and we believe it would cause damage to an ongoing relationship were they not able to talk to you directly. It may also include instances where we wish to refer you as an effective supplier.
Website Users: We use cookies to facilitate and improve your experience of our site and to provide and improve our services. By using our site you may also receive certain third-party cookies on your computer or device. Third-party cookies are those placed by websites, services, and/or parties other than Us.
We collect your data automatically via cookies.
We may share your information with providers of web analytics services, marketing automation platforms and social media services to offer a better website experience.
Other: There are a number of other types of data that we may receive and need to process, including but not limited to data received from Candidates and Staff (such as referrals, referees and emergency contacts).
We collect this data only when it is provided to us by third parties such as Candidates, Clients, or Staff.
We use this data for the purpose it was provided to us. Referees are contacted to provide references, emergency contacts are contacted in emergency situations, and referrals are contacted for the reason for which they were referred (for referrals, this may cause them to be considered in one of the other categories, such as a candidate)
We may share this data with third parties to provide them with references, or anywhere else where we believe an emergency situation requires that we do so.
Your Rights
Renew Recruitment Consultancy Limited have legal bases to process your data, but you still have rights in relation to it, and we are committed to upholding those rights. We have methods and processes in place to ensure that your rights are maintained, and you can action requests quickly and easily.
Right to be informed: Ensuring you are aware of information we hold, and how we will process it. For Candidates, this is ensured by providing you with clear and concise information about what we do with your personal data in this document. For all other categories in Data Subject, this will be done by directly contacting you.
Right of access: We will provide access to your data via phone or email, and may request verification of your ID before we share this information.
Right of Rectification: You can rectify inaccurate data, or complete it if it is incomplete. You can email or call our representative.
Right of Erasure: You can request we delete your data, and we will not object to doing so except in exceptional circumstances, in which case the reasons will be provided to you. For example: There may be legal reasons where we have to retain your data.
Note: We may need to retain some basic identifiers so that we don’t inadvertently add your data again in the future.
Right to restrict processing: In instances where you want us to keep the data, but do not want it processed. Our secure database allows us to place a lock on processing your data, but not delete it.
Right of data portability: Applicable to data held under the legal basis of “consent”, but not “legitimate interests”. In good faith we will usually try to help in all cases, and will only object in exceptional circumstances.
Right to object: If we are using your data on the legal basis of legitimate interests, and you object to us doing so, contact us and we will respond and attempt to rectify the situation without delay.
Right to withdraw consent: Where consent is the legal basis upon which we are processing your data, you may withdraw your consent.
Right to lodge a complaint with a supervisory authority: At Renew Recruitment Consultancy Limited, we are committed to giving you a positive candidate experience that is compliant with every aspect of data protection legislation. If you wish to lodge a complaint, we have internal measures to assist you, and hope that you will be able to resolve the issue through us directly. In the event you still wish to lodge a complaint, you should contact The Information Commissioner’s Office, contact details for which can be found later in this Policy.
Safeguarding your data
All data we hold is stored in a secure CRM and Applicant Tracking database, which is managed by our software provider Bullhorn. For more information about how Bullhorn approaches security, please visit https://www.bullhorn.com/uk/gdpr-commitment-statement/. All Staff with access to this database have password-protected accounts.
There is often an interim period where your data needs to be downloaded on to our computer systems so that we can upload it to our database. Data is kept on our computers for the shortest time possible, and is not kept on the computers for storage purposes. All computer systems used by Renew Recruitment Consultancy Limited are password-protected, and have security software installed.
Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If we do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the [Data Protection Act 1998] OR [GDPR]
Who to contact about your data, including accessing, deleting or amending
Our representative: If you wish to contact us in relation to your data, please call 01793 379044, or email our representative Harriet Janman at harriet@renewconsultancy.co.uk . Note that for all requests, we may need you to verify your identity or request further information.
Your local (UK) supervisory authority:
The Information Commissioner’s Office
www.ico.org.uk
Phone: 0303 123 1113
Email: casework@ico.org.uk
Post: Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Our legal bases for processing your data under GDPR
Under GDPR there are 6 lawful bases for processing data, and depending on the basis used it can affect your rights. Please see the table below.
| Right to erasure | Right to portability | Right to Object | |
| 1. Consent | Yes | Yes | No – but right to withdraw consent |
| 2. Contract | Yes | Yes | No |
| 3. Legal Obligation | No | No | No |
| 4. Vital Interests | Yes | No | No |
| 5. Public Task | No | No | Yes |
| 6. Legitimate Interests | Yes | No | Yes |
We use 1, 2, 3 and 6 as our legal bases depending on where and how your data is going to be processed. We do not expect to ever use 4 or 5, but in the exceptional and unlikely instance that we do, you will be immediately informed.
(1) Consent: The individual has given clear consent for you to process their personal data for a specific purpose. Consent must be a freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
(2) Contract: The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(3) Legal obligation: The processing is necessary for you to comply with the law (not including contractual obligations).
(6) Legitimate interests: The processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Note: We may hold your personal data under different bases. For example, if you consent to us forwarding your data to a client, the information that directly relates to that is processed under “consent”, but the information that we process under “legitimate interests” will continue to be processed using that lawful basis.
Candidates
We safeguard your data, and we welcome you to conduct user testing by requesting a feedback form from us by contacting Harriet@renewconsultancy.co.uk
When storing and using your data internally
We use the legal basis of “Legitimate Interests” – It is core to our recruitment business that we effectively match skilled people in our field of the power generation markets with clients who require those skills. As such, it is in our legitimate interests to hold Candidate CV’s on our secure database. Doing so is indeed necessary for us to provide a service to each individual Candidate. Due to the methods we use to collect our data, all Candidates will reasonably expect us to store, use and process that personal data in this way, in fact, it is likely to be the only reason that we received their data in the first place. As such, we are not infringing on any individual interests by processing data in this way, and there should be no negative impact.
We also offer an opt-out, which can be actioned by contacting our representative. For representative details, please see the contact links earlier in this Privacy Policy.
To apply to our clients on your behalf
We use the legal basis of “Consent” – We believe that it is very important to obtain your consent before passing your CV on to any of our clients. As such, we will require positive opt-in consent for each and every Client before we submit applications on your behalf. When we reach this stage of the Candidate experience, we will send you a separate email where you will be able to provide your consent.
You do not have to consent to having your details forwarded to any of our Clients, and declining to consent to any or all of the opportunities we provide to you will have no impact on our service to you in the future.
You are also able to withdraw your consent. To ensure we can continue to provide you the best service possible, we are likely to request information as to why you have changed your mind, but you are under no obligation to provide us with a reason, and it will not affect the service we offer. If you choose to withdraw your consent, we will inform the Clients which you have stated you are removing consent from. We will not inform clients where consent has not been withdrawn. Whilst we can guarantee it won’t affect the service we offer you, we cannot confirm whether or not it will affect how our Clients view that withdrawal. We aim to work with ethical clients, but we cannot make guarantees on what any Clients will do with your data after we have informed them that you have removed consent, as they have become a controller of that data, with their own legal basis for holding it.
Working with limited company contractors
We use the legal basis of “Contract” – We will need to enter into a contract with you, and our Clients, in order to provide your services to our clients, and to fulfil our contractual obligations to you.
Other reasons:
In various circumstances, we may process your data using the “legal” basis. We may need to retain information after having placed you in a role, or if there are legal proceedings that require us to keep your information.
Clients:
We use the basis of “legitimate interests” – We store your company data as well as the personal data of individuals in your organisation (including details of vacancies, notes on meetings etc). We may also send you recruitment-related material, such as salary surveys, or ask you to complete customer satisfaction surveys. This is all in our legitimate interest as a recruitment agency in order to provide a professional service to you.
Suppliers:
We use the basis of “legitimate interests” – We process your data so that we can receive your services smoothly and effectively. We also hold your financial details so we can fulfil our contractual obligations to you. It is in our legitimate interests to be able to receive those services/products, and also in our legitimate interests to pay you for those services/products so that we keep them!
Referees
We use the basis of “legitimate interests” – If we are provided with your details as a referee, we will need to contact you to obtain the reference. It is in our legitimate interests as a recruitment agency to be able to ensure that references are obtained. We also believe that you will reasonably expect us to use your data in this way.
Website Users:
Cookies are governed by the PECR and hence do not relate to the GDPR legal basis in this section. Any other information supplied to us by Website Users will place them in one of the above categories, such as Candidate or Client, and the relevant basis will apply. Our Cookie Policy is found later in this Privacy Policy.
Special Category Data
What is Special Category Data?
This is personal data which the GDPR says is more sensitive, and so needs more protection. For example, these may include: race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation. In particular, this type of data could create more significant risks to a person’s fundamental rights and freedoms. For example, by putting them at risk of unlawful discrimination.
How we process Special Category Data
We may need to process special category data, in particular, data relating to race where our Clients require security clearance, or health where there are special circumstances, or we may need to make particular provisions for you.
We process this data under Article 9(2) of the GDPR. Conditions: (a), (b), (d), (e), and (h).
We do not process special category data except where it is necessary to provide our service, or you have requested that we process it for any reason. The exception is where you have placed special category data on your CV, in which case we will not alter your CV to remove that data.
What Happens If Our Business Changes Hands?
We may, from time to time, expand or reduce our business, and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us.
In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
Cookies
Our site may place and access certain first-party cookies on your computer or device. First-party cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our site and to provide and improve our services. We have carefully chosen these cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using our site you may also receive certain third-party cookies on your computer or device. Third-party cookies are those placed by websites, services, and/or parties other than us. These cookies are not integral to the functioning of our site and your use and experience of our site will not be impaired by refusing consent to them.
All cookies used by and on our site are used in accordance with current cookie law.
Before cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however, certain features of our site may not function fully or as intended.
Certain features of our site depend on cookies to function. cookie law deems these cookies to be “strictly necessary”. Your consent will not be sought to place these cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that our site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Please contact us for a list of first-party and third-party cookies that may be placed on your computer or device.
Our site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our site is used. This, in turn, enables us to improve our site and the services offered through it. You do not have to allow us to use these cookies, however, whilst our use of them does not pose any risk to your privacy or your safe use of our site, it does enable us to continually improve our site, making it a better and more useful experience for you.
In addition to the controls that we provide, you can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept cookies but this can be changed. for further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete cookies on your computer or device at any time, however, you may lose any information that enables you to access our site more quickly and efficiently.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Glossary:
Data Subject: A broad term that covers each and every legal entity who we hold data on, including Candidates, Clients and any other entity we have specifically mentioned.
Candidate: Anyone who we hold information on where the purpose is to assist in securing them a job role with a Client. For the purpose of this Privacy Policy, this includes permanent employees, temporary employees, freelance workers and sub-contractors (whether single, or multiple contractors are involved).
Client: Any company we provide our services to, or are in contact with where there is a reasonable expectation that our services may eventually be provided.
Supplier: This includes, and only includes, entities who directly supply a service or product to Renew Recruitment Consultancy Limited, where we are the user of that service or product. For the purpose of this Privacy Policy it does not include contractors or freelancers where we sub-contract your services on our behalf to our Clients, as in that instance those entities are classed as Candidates.
Website Users: Anyone who uses https://renewconsultancy.co.uk/
Staff: Anyone previously employed, currently employed, or has accepted an offer to be employed by Renew Recruitment Consultancy Limited.
Any feedback you have on the way Renew Recruitment Consultancy Limited process data, or our descriptions of our processes and policies would be greatly appreciated.