1. DEFINITIONS AND INTERPRETATION
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of our Site;|
|“Cookie”||means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14 below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003|
2. INFORMATION ABOUT US
Our Site is owned and operated by McGinnis Loy Associates Ltd, a Limited Company registered in England under company number 8047462.
Registered address: Oak House, 72 Arbor Lane, Winnersh, Berkshire, RG41 5JD.
VAT number: GB 139 866 855
Email address: [email protected]
Telephone number: 01183 245 245
Postal address: Oak House, 72 Arbor Lane, Winnersh, Berkshire. RG41 5JD
Representative: Leslie Fearn
Email address: [email protected]
Telephone number: 01183 245 245 or 01889 390 380
3. WHAT DOES THIS POLICY COVER?
4. WHAT IS PERSONAL DATA?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers.
5. WHAT ARE MY RIGHTS?
Under the Data Protection Legislation, you have the following rights which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves initially however, so please contact us first, using the details in Part 15.
6. WHAT DATA DO YOU COLLECT AND HOW?
|Data Collected||How we Collect the Data|
|Identity information including Name, Title.||Online Form, Email, CV, Phone/Video Call.|
|Contact information including Address, Email Address, Telephone Numbers.||Online Form, Email, CV, Phone/Video Call.|
|Business information including Business Name, Job Title, Profession.||Online Form, Email, CV, Phone/Video Call.|
|Profile information including Contact Preferences, Business Interests, Login Details, Purchase History.||Cloud CRM system.|
|Technical information including IP Address, Browser type and version, Operating System.||Meta Data in Emails and Website Browsing.|
7. HOW DO YOU USE MY PERSONAL DATA?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
|What we Do||What Data we Use||Our Lawful Basis|
|Providing and managing your Account.||Contact information, employment preferences, account history.||Contract, Legal Obligation.|
|Preparing a professional CV on your behalf||Contact information, educational information, work/job information||Contract, Consent.|
|Verifying UK work eligibility||Biometric residence permit number, passport or national identity card||Contract, Legal Obligation|
|Verifying qualifications||Professional membership information, academic information||Contract, Legal Obligation|
|Compliance with Employment Agency legislation||Contact information, Professional membership information, academic information, identity information, residence information||Legal Obligation|
|Personalising and tailoring your experience on our Site.||User preferences.||Consent.|
|Administering our Site.||Contact information, employment information, support requests.||Contract, Consent.|
|Administering our business.||Contact information, employment information, academic information, billing information, preferences, account history.||Contract, Legal Obligation.|
|Supplying our services to you.||Contact information, employment information, academic information, preferences, account history.||Contract.|
|Managing payments for our services.||Business bank details, purchase history, preferences.||Contract, Legal Obligation.|
|Personalising and tailoring our services for you.||Purchase history, preferences.||Legitimate Interest – To offer the appropriate service to customers.|
|Communicating with you.||Contact information.||Contract, Legal Obligation, Legitimate Interest – Communicating with existing customers.|
|Supplying you with information by email and/or post that you have opted into (opt-out at any time by emailing us or clicking the unsubscribe links)||Contact information, preferences, history.||Consent.|
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information and news on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time. Third Parties whose content appears on our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. HOW LONG WILL YOU KEEP MY PERSONAL DATA?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long we Keep It|
|Identity Information including name, title, date of birth, gender.||36 months, unless there is a statutory requirement to store it longer.|
|Contact information including address, email address, telephone numbers.||36 months, unless there is a statutory requirement to store it longer.|
|Business information including business name, job title, academics, professional experience, UK eligibility to work.||36 months, unless there is a statutory requirement to store it longer.|
|Payment information including bank account numbers, card details.||36 months, unless there is a statutory requirement to store it longer.|
|Profile information including preferences and interests, username and password, purchase history.||36 months, unless there is a statutory requirement to store it longer.|
|Technical information including IP address, browser type and version, operating system.||36 months, unless there is a statutory requirement to store it longer.|
9. HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?
We store or transfer some or all of your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows: We transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission . We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission .
Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission . Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country. The security of your personal data is essential to us and to protect your data, we take a number of important measures including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so
10. DO YOU SHARE MY PERSONAL DATA?
11. HOW CAN I CONTROL MY PERSONAL DATA?
- In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails) or at the point of providing your details.
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. CAN I WITHHOLD INFORMATION?
13. HOW CAN I ACCESS MY PERSONAL DATA?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that timeframe. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Before Cookies are placed on your computer or device, you will be shown a button or pop-up requesting your consent to set those 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. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies. Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. 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 settings as detailed below, 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. The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|GA – Google Analytics||Site usage analytics||No|
|Pop-Up||Providing and stopping pop-ups on site||Yes|
|Mailchimp||Online form management||No|
|Gravity Forms||Website Form Processing||Yes|
and the following third-party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
|YouTube||Google – YouTube||Video Usage|
|Name of Cookie||First / Third Party||Provider||Purpose|
|GA||First||Google Inc||Website usage analytics|
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 including, but not limited to, login and personalisation settings. 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.
15. HOW DO I CONTACT YOU?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: [email protected]
Telephone number: 01183 245 245
Postal Address: Oak House, 72 Arbor Lane, Winnersh, Berkshire. RG41 5JD