Privacy Policy

•   SHAKESPEARE RECRUITMENT LTD

Shakespeare Recruitment Ltd is committed to protecting and respecting your privacy.

Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation that replaces the Data Protection.

Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post-Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.

Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of The  Data Protection Legislation, the data controller is Shakespeare Recruitment Ltd of 160 Kemp House, City Road, London, EC1V 2NX. we have a  nominated representative OR Data Protection Officer.

We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business).  We also provide the following other services such as training. We collect the personal data of the following types of people to allow us to undertake our business;

· Prospective and placed candidates for permanent or temporary roles;

· Prospective and live client contacts;

· Supplier contacts to support our services;

· Employees, consultants, temporary workers;

· We collect information about you to carry out our core business and ancillary activities.

Information you give to us or we collect about you.

This is information about you that you give us by filling in forms on our site www.shakespearerecruitment.co.uk (our site) or by corresponding with us by phone, e-mail, or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion, or survey, and when you report a problem with our site.

The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

Information we collect about you when you visit our website.

With regard to each of your visits to our site we will automatically collect the following information:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform;

information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through, and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Information we obtain from other sources.

This is the information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations. In this case, we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from, and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment, and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors.] We may receive information about you from them for our recruitment services and ancillary support services.

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways,

To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products, and services that you request from us or we think will be of interest to you because it is relevant to your career or your organisation.

To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with, or enquired about.

The core service we offer to our candidates and clients is the introduction of candidates to our clients for temporary or permanent engagement.  However, our service expands to supporting individuals throughout their careers and to supporting businesses’ resourcing needs and strategies.

Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation, and consent for specific uses of data.

We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

We will rely on legal obligation if we are legally required to hold information on to you to fulfill our legal obligations.

We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent if legally required.  Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).

Our Legitimate Business Interests

Our legitimate interests in collecting and retaining your personal data are described below:

As a recruitment business and recruitment agency, we introduce candidates to clients for permanent employment, temporary worker placements, or independent professional contracts.  The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.

To support our candidates’ career aspirations and our clients’ resourcing needs, we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

To maintain, expand and develop the business we need to record the personal data of prospective candidates and client contacts.

Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email, or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Other uses we will make of your data:

· Use of our website;

· To notify you about changes to our service;

· To ensure that content from our site is presented most effectively for you and your computer.

· We will use this information:

· To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

· To improve our site to ensure that content is presented most effectively for you and your computer;

· To allow you to participate in interactive features of our service when you choose to do so;

· As part of our efforts to keep our site safe and secure;

· To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

· To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

We do not undertake automated decision-making or profiling. We do use our computer systems to search and identify personal data by parameters set by a person. A person will always be involved in the decision-making process. 

Cookies  

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies, we use and the purposes for which we use them see our Cookie notice please contact us and we will be happy to provide you with this information.

Disclosure of your information inside and outside of the EEA

We will share your personal information with:

Any member of our group both in the EEA and outside of the EEA.

Selected third parties include:

· Clients to introduce candidates to them ;

· Candidates to arrange interviews and engagements;

· Clients, business partners, suppliers, and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;

· Subcontractors including email marketing specialists, event organizers, payment and other financial service providers.

· Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. [We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience];

· Analytics and search engine providers that assist us in the improvement and optimisation of our site;

· Credit reference agencies, our insurance broker, compliance partners, and other sub-contractors to assess your suitability for a role where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

· If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

· If Shakespeare Recruitment Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

· If we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Shakespeare Recruitment Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The lawful basis for the third-party processing will include:

· Their legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;

· Satisfaction of their contractual obligations to us as our data processor;

· For the purpose of a contract in place or contemplation;

· To fulfil their legal obligations.

Where we store and process your personal data  

The data that we collect from you may be transferred to and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing, or processing. SHAKESPEARE RECRUITMENT Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 site; 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.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.  Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.

We do the following to try to ensure our data is accurate:

Before making an introduction, we check that we have accurate information about you

we keep in touch with you so you can let us know of changes to your personal data.

We segregate our data so that we keep different types of data for different periods.  The criteria we use to determine whether we should retain your personal data includes:

· The nature of the personal data;

· Its perceived accuracy;

· Our legal obligations;

· Whether an interview or placement has been arranged; and

· Our recruitment expertise and knowledge of the industry by country, sector, and job role.

We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data onto our database unless requested to do so.

For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

Our current retention notice is available upon request.

Your rights  

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required before using your personal data for marketing purposes.

You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right to opt-out at any time by contacting us on admin@shakespearerecruitment.co.uk, from time to time, containing links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The GDPR provides you with the following rights

· Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

· Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

· Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object to where we are processing your personal information for direct marketing purposes.

· Request the restriction of processing of your personal information. 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.

· Request the transfer of your personal information to another party in certain formats, if practicable.

· Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link:  https://ico.org.uk/concerns/

Access to information  

The Data Protection Act 1998 and the GDPR give you the right to access information held about you.  We also encourage you to contact us to ensure your data is accurate and complete.

Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force). Prior to 25th May 2018, any access request under the Data Protection Act will be subject to a fee of £25 to meet our costs in providing you with details of the information we hold about you.

A subject access request should be submitted to info@shakespearerecruitment.com No fee will apply once the GDPR comes into force.

Changes to our privacy notice  

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Contact  

Questions, comments, and requests regarding this privacy notice are welcomed and should be addressed to admin@shakespearerecruitment.co.uk.

How we use your personal data:

- We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency, and pattern of your service use.

- We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you. 

- We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth,  relationship status, interests and hobbies, educational details, and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your explicit consent or our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

- We may process your personal data that are provided for the course of the use of our services (“service data”). The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you. 

- We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. 

- We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website  (“transaction data”). The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. 

- We may process information that you provide to us to subscribe to our email notifications and/or newsletters (“notification data”). The notification data may be processed to send you the relevant notifications and/or newsletters. The legal basis for this processing is your explicit consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

- We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed to communicate with you and record-keeping.

- We may process personal data for the use of job applications. This data may include Your name, address, town/city, postcode, email address, telephone, CV content which may include prior work history and education history,   hobbies, and interests. The source of this data is your CV/Resume. This data may be processed for job applications. The legal basis for this processing is your consent when you apply for a job or register on this website or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

- Please do not supply any other person’s data to us, unless we prompt you to do so.

We will retain your data as follows:

- Personal data categories or categories will be retained for a minimum period of 1 year following the date of collection, and for a maximum period of 6 years  (AS per the OFSTED Rules) following the date, the data was collected.

- In some cases, we can't specify in advance the periods for which your personal data will be retained. In such cases, we will      determine the period of retention based on the following criteria:

- The period of retention of your collected data will be determined based on up-to-date personal information such as CV, email, or telephone number.

- If the candidate has got the DBS certificate issue from ESP, the Data must be retained for 7 years as per the OFSTED guidelines.

- If the Candidates already have got the DBS Certificate from external sources,      his or their Data is subjected to the above-mentioned retention policies.

Security of personal data:

- We have appropriate technical and organisational precautions & principles in place to secure your personal data and to prevent the loss, misuse, or alteration of your personal data.

- We will store all your personal data on secure encrypted servers.

- The following personal data will be stored by us in encrypted form: password(s).

- Data relating to your inquiries and financial transactions that are sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.