|Company Name:||SGR Legal Ltd|
|Company Contact details:||David Bell Company Director|
SGR Legal is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws.
- Collection and use of personal data
- Purpose of processing and legal basis
- Legitimate interest
- Statutory/contractual requirement
- Recipients of data
- Information to be provided when data is not collected directly from the data subject
- Categories of data
- Sources of data
- Overseas transfers
- Data retention
- Your rights
- Automated decision making
- Login files
- Links to external sites
- Sale of the business
- Data security
- Changes to this privacy statement
- Complaints or queries
1.Collection and use of personal data
a. Purpose of processing and legal basis
SGR Legal will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.
If you have opted-in we may also send you marketing information and news via email/ text. You can opt-out from receiving these at any time by unsubscribing when you receive these communications from us.
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have
- To fulfil a contractual obligation that we have with the individual or in order to take steps at the request of the individual to enter into a contract.
- For the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
- Where it is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.
b. Legitimate interest
This is where SGR Legal has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where SGR Legal has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- Managing our database and keeping work-seeker records up to date
- Providing work-finding services to you and our clients
- Contacting you to seek your consent where we need it
- Giving you information about similar products or services that you have used from us recently
c. Statutory/contractual requirement
SGR Legal has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide work-finding services to you.
d. Recipient/s of data
SGR Legal will process your personal data and/or sensitive personal data with the following recipients:
- Clients (whom we may introduce or supply you to)
- Former employers whom we may seek references from
- Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
- Other recruitment agencies in the supply chain
2. Information to be provided when data collected not from the data subject
Categories of data:
In some cases we may have collected the following personal information from you prior to seeking consent. However where this information has been collected you will be notified and SGR Legal will abide by the rules, guidance and obligations of GDPR.
- Name, address, mobile number, email
- National insurance no.
- Nationality (through right to work check)
- Past employment
- Lifestyle, personal interests, hobbies etc.
Sensitive personal data:
- Health information including whether you have a disability
- Criminal conviction
- Identification reference numbers e.g. passport, driving licence etc
- Political opinions
- Racial or ethnic origin
- Religious or philosophical beliefs
- Trade union membership
- Genetic data
- Biometric data
- Relationship information
Source of the personal data:
There are a number of resources that we use as a recruitment firm in addition to resources that are available using publicly accessible sources on the internet. Sources of information may include, but are not limited to, the following:
- From jobs boards, Internet searches, LinkedIn, Facebook and other social media sites.
- A former employer
- A referee whose details you previously provided to us
- Software providers who we use to support our services
3. Overseas Transfers
The Company may transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. This transfer of information would only be for candidates seeking overseas employment and would only be performed with the consent of the candidate.
4. Data retention
SGR Legal will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
In the case of temporary workers (employed and paid by SGR Legal) we must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.
Where SGR Legal has obtained your consent to process your personal data (in some cases including sensitive personal data), we will do so in line with your given consent. Upon expiry of that period SGR Legal will seek further consent from you. Where consent is not granted SGR Legal will cease to process your personal data.
5. Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company processes on you;
- The right to rectification of your personal data;
- The right to the erasure of your personal data in certain circumstances;
- The right to restrict the processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to SGR Legal processing your Personal Data you have the right to withdraw that consent at any time by contacting David Bell, Company Director, email: firstname.lastname@example.org, tel: 03333057530, PO Box 8438, ASHBOURNE, DE6 9DZ. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent or that which is done according to another legal basis.
There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content. Most web browsers allow some control of most cookies through the browser settings.
7. Log Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
8. Links to external websites
The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.
9. Sale of business
If the Company’s business is sold or 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 t new owners of the business.
10. Data Security
The Company takes every precaution to protect our users’ information. Your data is encrypted and stored within a secure database. This information is only accessible by those that are granted permission through secure login. Computers used by SGR Legal are all either locked using the user’s fingerprint or (where fingerprint is not available) password. To protect our computer systems firewalls are used to prevent security breaches. If information is provided to us using a non-secure method, this data will be transferred to our secure database and the source will be suitably destroyed.
Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.
The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.
If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.
If you have any questions about the security at our website, you can email David Bell – david@SGRLegal.com
11. Changes to this privacy statement
We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.
12. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: David Bell, Company Director, email: email@example.com, tel: 03333057530, PO Box 8438, ASHBOURNE, DE6 9DZ.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.