Company name: Zetter Ltd trading as Zetter Recruitment (‘the Company’)
Company contact details: Ursula Colman, Zetter Recruitment, St John’s Innovation Centre, Cowley Road, Milton, Cambridge, CB4 0WS
email@example.com (Data Protection lead)
Date: 1 June 2019
Zetter Recruitment is a recruitment business which provides work-finding services to its clients and work-seekers. We must process personal data (including sensitive personal data) so that we can provide these services – in doing so, Zetter Recruitment acts as a data controller.
You may give your personal details to us 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. Zetter Recruitment 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.
1. Collection and use of personal data
a. Purpose of processing and legal basis
Zetter Recruitment 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 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 clicking “unsubscribe” when you receive these communications from us.
We may also collect personal identification information when users visit our website, register on the website, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our website. Users may be asked for, as appropriate, name, email address, mailing address, phone number. Users may, however, visit our website anonymously.
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:
Where we have a legitimate interest
To comply with a legal obligation that we have
To fulfil a contractual obligation that we have with you
b. Legitimate interest
This is where Zetter Recruitment 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 Zetter Recruitment 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;
In order to provide a personalised and efficient recruitment service, we would like to provide tailored job recommendations and relevant articles related to your career, job search, the sales industry and the eastern region. To deliver these services, we think it is reasonable to process your data in order to send you the most relevant and appropriate content. From time to time, we would also like to invite candidates and clients to take part in surveys relating to recruitment which aim to develop careers and prospects within the industry you work in.
c. Statutory/contractual requirement
Zetter Recruitment 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. Recipients of data
Zetter Recruitment 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
The Recruitment and Employment Confederation
Insurers and legal advisers
IT and CRM providers
Other software providers such as Hinterview video software, Herefish and Cloudcall
Our agents and service providers
A third party who acquires our business
Law enforcement and regulatory agencies in connection with any investigation to help prevent unlawful activity or as overwise required by law
e. Transfer of data outside of the European Economic Area
2. Information to be provided when data collected not from the data subject
Categories of data:
Name, address, phone number(s), email(s), CV, work history and any other relevant information provided to us when you approach us about work-finding services
Links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website
Details of your visits to our website and the resources that you access including, but not limited to, traffic data, location data, weblog statistics and other communication data
Call recordings of inbound and outbound calls with you
Video interviews we have had with you
Nationality (through right to work check)
Source of the personal data:
From sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, and personal recommendations
A former employer
A referee whose details you previously provided to us
Software providers who we use to support our services
Cookies listed in section 7
When collecting information about you by phone correspondence, our calls are recorded for training and quality monitoring purposes. If you do not wish for this to be the case, please inform us at the outset of the call.
3. Overseas transfers
Zetter Recruitment 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.
4. Data retention
Zetter Recruitment 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.
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 Zetter Recruitment has obtained your consent to process your personal data, unless required to retain data for a longer period as outlined above, we will not retain your personal data for longer than three years. Upon expiry of that period Zetter Recruitment will seek further consent from you. Where consent is not granted we 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 Zetter Recruitment processes on you
The right of access to the personal data Zetter Recruitment processes on you
The right to rectification of your personal data
The right to erasure of your personal data in certain circumstances
The right to restrict 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 a public or legitimate interest
The right not to be subjected to automated decision making and profiling
The right to withdraw consent at any time
Where you have consented to Zetter Recruitment processing your personal data you have the right to withdraw that consent at any time by contacting Ursula Colman or emailing firstname.lastname@example.org. 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 which is done according to another legal basis.
There may be circumstances where Zetter Recruitment 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 Zetter Recruitment 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.
6. Automated decision-making
We may undertake automated decision making or profiling. We use automated communication software (Herefish) to keep in touch with candidates and clients via email and text. We do use our computer systems to search and identify personal data in accordance with parameters set by a person.
8. Log files
We use IP addresses to analyse trends, administer the website, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
9. Links to external websites
Zetter Recruitment’s website may contains links to other external websites. Please be aware that Zetter Recruitment is not responsible for the privacy practices of such other websites. When you leave our website 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 Zetter Recruitment’s website.
10. Sale of business
If Zetter Recruitment’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 the new owners of the business.
11. Data security
Zetter Recruitment takes every precaution to protect our users’ information. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Only employees who need the information to perform a specific job (for example, consultants, our accounts person or a marketing assistant) are granted access to your information.
Zetter Recruitment 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, Zetter Recruitment 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 us, email@example.com
12. 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.
13. Complaints or queries
Where you request your data to be updated, deleted or for us to provide you with a copy of the data we will action this within one week from when the request is received. All requests should be emailed to firstname.lastname@example.org
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: email@example.com
You also have the right to raise concerns with the 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.