Rework Recruitment Group Ltd (we) is a company registered in England and Wales under company number 03940716 and whose registered office is at 1 Waterside, Station Road, Harpenden, AL5 4US.
1 What is the purpose of this document?
1.1 This transparency notice describes how we collect and use personal information about you during and after your relationship with us.
1.2 We are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.
1.3 This notice applies to all candidates collectively referred to in this notice as 'Candidates'. It also applies to clients, contractors, service providers and suppliers to our business and to our employees.
2 What personal information are we collecting?
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).
There are special categories of more sensitive personal data which require a higher level of protection (see section 3).
2.1 During the registration and application process we will collect, store and use the following categories of personal information about Candidates and we also collect applicable information from our employees during the course of their employment:
2.1.1 your name, addresses, telephone numbers, and personal email addresses and username & passwords for system access where applicable;
2.1.2 your age, gender and date of birth;
2.1.3 details of your business or organisation;
2.1.4 references;
2.1.5 a copy of your passport;
2.1.6 proof of your experience, training, qualifications and authorisations relevant to providing interpretation and/or translation services;
2.1.7 if you are self-employed, proof of your registration for self-employment with HMRC;
2.1.8 confirmation as to whether you are willing to work unsociable hours;
2.1.9 performance information including clients' opinions about your performance;
2.1.10 marital status and dependants
2.1.11 next of kin and emergency contact information;
2.1.12 your National Insurance number;
2.1.13 your bank account details and tax status information;
2.1.14 your salary, annual leave, pension and benefits information;
2.1.15 your right to work documentation (for example a passport number or Immigration Status Document as set out in the Home Office's right to work checklist, which can be found here: https://www.gov.uk/government/publications/right-to-work-checklist);
2.1.16 work history and employment records (including job titles, location of employment or workplace and notice period);
2.1.17 your compensation history;
2.1.18 photographs;
2.1.19 performance information;
2.1.20 other information you voluntarily provide in a CV or cover letter or as part of the application process
2.2 During the course of your working relationship with us / your position (if placed) we also collect:
2.2.1 your location;
2.2.2 information as necessary to confirm performance of Services in accordance with the 'Job Details' provided by a client; and
2.2.3 reviews and feedback from clients.
2.3 If you are a contractor or supplier of services to the business we collect the following categories of personal information about you:
2.3.1 your name, title and business contact information including addresses, telephone numbers and email addresses;
2.3.2 we will perform due diligence in the form of credit checks on companies, including checking photographic identification and proof of address of directors and verification of the company registration details;
2.3.3 any other information to enable performance of a contract
3 Particularly sensitive personal information
3.1 We may also collect, store and use the following special categories of more sensitive personal information:
3.1.1 information about your physical or mental health, or disability status;
3.1.2 information about your race or ethnicity (from your passport) religious, philosophical or moral beliefs, or sexual orientation;
3.1.3 genetic information and biometric data;
3.1.4 trade union membership information; and
3.1.5 information about criminal convictions and offences.
3.2 We will use your sensitive information as listed above in the following ways:
3.2.1 we will use your health information to assess your fitness to work, to provide appropriate workplace adjustments or to monitor and manage sickness absence and administer benefits;
3.2.2 we use your passport to verify your identity and right to work in the UK;
3.2.3 we use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or sexual orientation, to ensure meaningful opportunity monitoring and reporting;
3.2.4 if it is appropriate given the nature of the role and where we are legally able to do so, we will use information about any spent or unspent criminal convictions and offences to assess your suitability (or to enable our Clients to assess your suitability) for certain positions. This may include carrying out background checks, where necessary; and
3.2.5 if required to perform services of the contract
4 How will we collect your personal information?
4.1 We will collect personal information from you directly when you register to use our Services or by entering information onto our website.
4.2 We will collect information throughout the registration/application and placement process, either directly from you or from other referrals.
4.3 We will sometimes collect additional information from third parties including former employers or other background check agencies.
4.4 We will collect information from publicly available sources including social media sites such as LinkedIn and Facebook.
5 For what purpose will we use your personal information?
5.1 We will use all of the categories of information at section 2 above primarily to perform our contract, or to take steps prior to entering into this contract, with you. To do this, we will process your personal information in the following situations:
5.1.1 to provide our services to you. Our services consist of Recruitment;
5.1.2 to contact you to provide support in relation to your work;
5.1.3 to contact you about jobs that we think you might be interested in;
5.1.4 to manage our relationship with you; and
5.1.5 to monitor and review your performance in accordance with our contract including to resolve any dispute with a client.
5.2 We will also use your personal information to:
5.2.1 check you are legally entitled to work in the UK;
5.2.2 ascertain your fitness to work;
5.2.3 conduct data analytics studies to review and better understand employee retention and attrition rates. Personal information will be anonymised before we store the result of such studies with third parties;
5.2.4 making a decision about your eligibility to do a job;
5.2.5 checking your self-employed status for tax purposes;
5.2.6 paying you;
5.2.7 administering the contract we have entered into with you;
5.2.8 assessing qualifications for a particular job or task;
5.2.9 dealing with legal disputes involving you, or other workers;
5.2.10 to prevent fraud;
5.2.11 to monitor your use of our information and communication systems to ensure compliance with our IT policies; and
5.2.12 to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
6 What are the legal bases for us to use your personal information?
6.1 We will only use your personal information when the law allows us to do so. Most commonly, we will use your personal information in the following circumstances:
6.1.1 where it is necessary to perform the contract we have entered into with you;
6.1.2 where we need to comply with a legal obligation; and
6.1.3 where it is necessary for our legitimate interests (or those of a third party) to ensure the smooth running of our or their business. We are allowed to do this as long as our or their activities do not disproportionately intrude your privacy.
6.2 We will also use your personal information in the following situations, which are likely to be rare:
6.2.1 where we need to protect your interests or someone else's interests;
6.2.2 or otherwise with your consent.
6.3 Some of the above grounds for processing your personal information will overlap, and there may be several grounds which justify our use of this information.
7 Who are we going to share your personal information with and what will they do with it?
7.1 Unless this would be unfair to you, we have a legitimate interest in the smooth running of our business and in promoting and growing it. To do this, we will share your personal data with:
7.1.1 our clients as prospective employers;
7.1.2 any agency or service company with which you are contracted to work;
7.1.3 the Department of Employment;
7.1.4 to HMRC and any other government bodies as required by law;
7.1.5 any other potential employers that you have agreed we may contact on your behalf; and
7.1.6 if we have previously placed you in a contractor or permanent position, we may provide a reference (without your prior consent) to any future employer we place you with.
7.2 If you object to our sharing or continuing to use your personal information with any specific recruiter or potential employer please contact us at info@novouk.com.
7.3 We may share your data with third-party service providers (including contractors and designated agents), and other entities that provide certain services on our behalf. The following activities are carried out by third-party service providers: IT support and mailing services.
7.4 All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.
8 If you fail to provide personal information
8.1 In order for us to provide our service, you may be required to provide the personal information set out in 2.1 of this notice. If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as introducing you to our clients or providing employment guidance).
Your duty to inform us of changes
8.2 It is important that the personal information we hold about you is accurate and current. You must keep us informed if any of your personal information changes during your working relationship with us by email to info@novouk.com.
9 Change of purpose
9.1 We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
9.2 Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.
10 Automated Decision-Making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making where we have notified you of the decision and where it is necessary to perform the contract with you.
If we make an automated decision on the basis of any particularly sensitive personal information, we will only do so with your explicit written consent unless it is justified in the public interest, and we have taken appropriate measures to safeguard your rights.
10.1 We do not envisage that any decisions will be taken about you using automated means, however we will notify you if this position changes.
11 Where will we store your personal information?
11.1 Any personal information that you submit to us will be held on secure servers, based within the European Economic Area (EEA).
Transferring information outside the EEA
11.2 We may transfer information about you outside the EEA. We will only do so where necessary for a specific job opportunity and with your consent.#
12. Data Security
12.1 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
13 How long will we use your personal information for?
13.1 We will keep your personal information 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.
13.2 For all Candidates that we have not placed, we will keep your personal information in our database for 6 years from the date you register with us, unless you tell us otherwise plus up to 12 months for our internal processes to securely review and delete inactive records.
13.3 For Candidates that are actively working for us, we will keep your personal information for as long as you are actively working on a job for one of our clients. For Candidates we have placed previously that are no longer actively working for us, we will keep your personal information in our database for 6 years from the completion of your last job, unless you tell us otherwise plus up to 12 months for our internal processes to securely review and delete inactive records.
14 Your rights in relation to our processing of your personal information
14.1 You have the right to be informed about what we are doing with your personal information. We do this by providing you with this Transparency Notice. If we change what we are doing we will provide you with an updated version of this notice.
14.2 You have the right to object to the processing of your personal information.
14.3 You have the right to request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
14.4 If the personal information we hold about you is incorrect or out of date you can ask us to correct it.
14.5 You have the right to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you ask us to delete your personal information we will not be able to provide our services to you.
14.6 You have the right to ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate and we want to verify the position, or if our processing is unlawful but you do not want us to erase your personal information, or for some other limited circumstances. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. If you ask us to restrict our use of your personal information, we may not be able to provide you with our services.
14.7 You can also ask us to send another organisation information that you have provided to us in a format that can be read by computer.
14.8 Where we rely on consent to process your personal information you have the right to withdraw that consent.
14.9 If you want to exercise any of your rights set out at 14.1 to 14.8, please contact info@novouk.com.
14.10 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
15 Changes to this transparency notice
15.1 We reserve the right to update this transparency notice at any time, and we will provide you with a new transparency notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
15.2 If you have any questions about this transparency notice, please contact info@novouk.com.
16 Complaints Procedure
16.1 If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner's Office: ico.org.uk.
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