Privacy Notice/Policy

Introduction

At Austen Lloyd your privacy is very important to us, and we are committed to protecting and safeguarding your personal data and your data privacy rights. This privacy notice explainshow we look after your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role or are providing you with our servicesand will informyou what we do with your personal data, how we collect, use and process your personal data, and tell you about your privacy rights and how the law protects you, and how we comply with our legal obligations under such.

Austen Lloyd is a recruitment business which provides work-finding services to its clients and work-seekers. Austen Lloyd (“The Company”) must process personal data (which may inadvertently include 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 or via our website, or we may collect them from another source such as a jobs board or a publicly available source. 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 and we will only use your personal data in accordance with these terms.

1. Important information and who we are

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) the company responsible for your personal data is Austen Lloyd Limited

Purpose of this privacy notice

This privacy notice aims to give you information on how Austen Lloyd collects and processes your personal data. This privacy noticeis to be read in line with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

We are a controller and responsible for your personal data.

We have a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Full name of legal entity: Austen Lloyd Limited
Name or title of DPO: Matthew Bird
Email address: matthew@austenlloyd.co.uk
Postal address: 16 Queen Square, Bristol, BS1 4NT

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to try to deal with your concerns beforehand so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 25th May 2018

It is important to point out that we may amend this Privacy Policy from time to time

It is important that the personal data we hold about you is accurate and current. Please therefore also keep us informed if your personal data changes during your relationship with us.

Third-party links

We are not responsible for the privacy policies of any third parties. We thereforemake you aware you may wish to read their privacy notices usually available on their websites.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). The Company has collected your personal data (which may inadvertently 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 or vacancies that our clients are looking to fill or where we think they would be interested in a candidate with your skill set and experience or where developing and managing our services and relationship with you and our clients.

In the course of our dealings therefore, we may need to collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

We do not collect Special Categories of Personal Data about you unless you have chosen to declare such to us (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

We do not collect unless you have chosen to declare such to us or we are required to do so by law or otherwise any information about criminal convictions and offences.

If you fail to provide personal data:Where we need to collect personal data by law, or under the terms of a contract and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected

We use different methods to collect data from and about you including through:

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances, and the legal bases we rely upon to offer these services to you are:

Therefore, note that we may not be relying solely on consent as the legal basis for processing your personal data.

As we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

We may use your Personal Data, Contact, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which jobs may be relevant to you.

You will receive communications on jobs from us if you have requested information from us or if we have provided you with recruitment services previously and, in each case, you have not opted out of receiving such alerts.

We will not share your personal data with anyone outside our company for general marketing purposes unless we obtain your prior consent.

Where you opt out of receiving job alert communications, this will not apply to personal data provided to us as a result of recruitment services we have already provided to you or a potential employer.

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain why we need to do so and the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

In addition to our client(s), who will then also become a data controller(s) we may have to share your personal data with the parties set out below.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We are not required in the course of our day to day business likely to need to transfer your personal data to any external third parties based outside the European Economic Area (EEA). However, should thisever be the case we will let you know in advance, and will beforehandensure a similar degree of protection is afforded to it.

7. Data security

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.

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.

8. Data retention

We 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.

Different laws may require us to keep different data for different periods of time.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we have to keep basic information about our clients and candidates (including Contact, Identity, Financial and Transaction Data) for some time after they cease being a client or candidate for tax and contractual purposes.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Further details of these rights are set out below.

If you wish to exercise any of the rights set out above, please contact our DPO: Matthew Bird.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances:There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting 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.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Except where other time limits may apply, we will endeavor to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is more complex. In this case, we will notify you and keep you updated.

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