Enjoy Recruitment Group Privacy Notice
The Company (Enjoy Recruitment Group Ltd – trading as Creative Mettle) is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
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 we will only use your personal data in accordance with the terms of the following statement.
1. Information we may collect from you
You may give your personal details to the Company directly, such as on an application or registration form or via our websites www.enjoyrecruitmentgroup.co.uk / www.creativemettle.co.uk or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our website, subscribe to our service, participate in discussion boards or other social media functions on our site, enter a promotion or survey, during the course of any other activity commonly carried out on our site and when you report a problem with our site.
The information you give us may include (but not limited to) the information given within your application forms such as your name, contact details, personal description, job history, qualifications, emergency contact details, bank details, right to work documentation, DBS, health and disability, criminal convictions and photograph.
We may collect information from another source such as a jobs board, clients with whom you are placed or referees.
We may also hold information relating to correspondence with or about you, for example, letters to you about a pay rise or, (at your request), a letter to your mortgage company confirming your salary; information needed for payroll, benefits and expenses purposes; sickness and other absence; information needed for equal opportunities monitoring policy; and records relating to your career history, such as training records, appraisals, other performance measures and, where appropriate, disciplinary and grievance records or complaints.
Regarding each of your visits to our website we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, 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), and methods used to browse away from the page.
2. Collection and use of personal data
a. Purpose of processing and legal basis
The Company 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. The legal bases we rely upon to offer these services to you are:
- Legitimate interest
- Legal obligation
- Contractual obligation
b. Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests are as follows:
- Due diligence, including for example Criminal Record disclosure, DBS checks, DVLA checks;
- for the establishment, exercise or defence of legal claims;
- Personalisation, to enhance and personalise your customer experience;
- Individual rights, to prevent unwanted processing of personal data of individuals who exercise their right to be forgotten;
- Personal data transferred in an acquisition;
c. Recipient/s of data
The Company will process your personal data with the following recipients:
- Government bodies (e.g. the HMRC, DWP)
- The company’s professional advisors (e.g. accountants, lawyers, HR advisors)
- External service providers offering services to support our fulfilment of your contract of employment (e.g. pensions providers, financial advisers, external payroll services, database / CRM providers)
- Other lawful means required for the fulfilment of your contract of employment/terms of engagement
d. Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
- Withdrawal of part or all the services you are requesting we provide
3. Data retention
The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
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.
Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our Data Deletion policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.
The company will retain your personal data and sensitive personal data for a period of six years from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. This period may be reduced on receipt of a Deletion Request from you and providing there are no legal obligations or legitimate interest reasons which require us to retain the personal data and/or sensitive personal data for a longer period.
4. Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company 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; and
- The right to withdraw consent at any time.
Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by writing to the Company Compliance Manager who is based at the Head office in Cheltenham, Gloucestershire. See our website for contact details.
The Company will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:
- Is necessary for the entering into or performance of a contract between the data controller and the individual;
- Is authorised by law; or
- The individual has given their explicit consent.
5. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it, please contact:
The Company Compliance Manager who is based at the Head office in Cheltenham, Gloucestershire or visit our website and follow our Complaints Procedure.
You also have the right to raise concerns with 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.