The General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679) is a regulation which 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.
Your rights under the GDPR are set out in this notice.
For the purposes of data protection legislation in force, the data controller is SixteenFifty Limited of 196 Demesne Road, Wallington, Surrey, SM6 8EN
The Data Protection Officer is John Cocklin
Who SixteenFifty are and what they do
SixteenFifty are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (the business). Personal data is collected of the following types of people to allow them undertake their business;
- Prospective and placed candidates for temporary roles;
- Prospective and placed candidates for permanent roles;
- Prospective and live client contacts;
- Supplier contacts to support their services;
- Employees, consultants, temporary workers;
You may have applied directly to SixteenFifty or they may have found your details from a job board or social networking site.
SixteenFifty collects information about you to carry out their core business and ancillary activities.
Information you give to SixteenFifty or they collect about you.
Information that you provide by filling in forms on their site www.wearesixteenfifty.com or by corresponding with them by phone, e-mail or otherwise.
Information contained in your CV. On occasion this may include sensitive personal data such as details of criminal convictions or ethnic origin.
Information you provide when you register to use the site, subscribe to their services, attend their events, participate in discussion boards or other social media functions on the site, enter a competition and promotion or survey and when you report a problem with the site.
If you contact SixteenFifty, they may keep a record of correspondences.
Information SixteenFifty obtains from other sources.
This is information SixteenFifty may obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, and personal recommendations. In this case SixteenFifty will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact they hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose they intend to retain and process your personal data.
SixteenFifty work closely with third parties including business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. SixteenFifty may receive information about you from third parties for the purposes of their recruitment services and ancillary support services.
Purposes of the processing and the legal basis for the processing
SixteenFifty may use information held about you in the following ways:
To enable SixteenFifty to submit your CV for general applications, specific jobs, or to subscribe to their job alerts.
To provide you with information or services that you request from SixteenFifty or which they feel may interest you.
To carry out the obligations arising from any contracts entered into between you and SixteenFifty.
Where SixteenFifty engages a person to work for them, there are other statutory obligations that must be compiled with including payroll, tax, social security, HMRC reporting requirements, and any other law or regulation.
They 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.
SixteenFifty’s Legitimate Business Interests
SixteenFifty’s legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency they introduce candidates to clients for temporary worker placements, permanent employee placements or independent professional contracts. The exchange of personal data of their candidates and their client contacts is a fundamental, essential part of this process.
In order to support their candidates’ career and their clients’ resourcing needs they require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop SixteenFifty’s business they need to record the personal data of prospective candidates and client contacts.
Should SixteenFifty want or need to rely on consent to lawfully process your data they will request your consent orally, by email or by an online process for the specific activity they require consent for and record your response on their system. Where consent is the lawful basis for their processing you have the right to withdraw your consent to this particular processing at any time.
Other uses SixteenFifty will make of your data:
- to notify you about changes to their service;
- to administer the site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to allow you to participate in interactive features of their service, when you choose to do so;
- as part of their efforts to keep the site safe and secure;
- to measure or understand the effectiveness of advertising they serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of the site about goods or services that may interest you or them.
SixteenFifty do not undertake automated decision making or profiling. SixteenFifty do use computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
Disclosure of your information inside and outside of the EEA
SixteenFifty will disclose your personal information to third parties:
- They will send your personal information, including sensitive personal information, to their clients in order for them to apply for jobs on your behalf
- Where they have retained your personal information to provide services, at the request of their client, such as reference, qualification and reference checking services or the verification or any data provided by you
- In the event that they sell or buy any business or assets, in which case they will disclose your personal data to the prospective seller or buyer of such business or assets
- If SixteenFifty 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
Where SixteenFifty store and process your personal data
The data that SixteenFifty 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 their recruitment services. By submitting your personal data, you agree to this transfer, storing or processing. SixteenFifty will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
Where they have given you (or where you have chosen) a password which enables you to access certain parts of the site, you are responsible for keeping this password confidential. SixteenFifty ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although SixteenFifty will do their best to protect your personal data, they cannot guarantee the security of your data transmitted to the site; any transmission is at your own risk. Once SixteenFifty have received your information, they will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
SixteenFifty understand their legal duty to retain accurate data and only retain personal data for as long as they need it for their legitimate business interests and that you are happy for them to do so. Accordingly, SixteenFifty have a data retention notice and run data routines to remove data that they no longer have a legitimate business interest in maintaining.
SixteenFifty does the following to try to ensure their data is accurate:
Prior to making an introduction they check that they have accurate information about you they keep in touch with you so you can let them know of changes to your personal data
The criteria SixteenFifty will use to determine whether they should retain your personal data includes:
- the nature of the personal data;
- its perceived accuracy;
- legal obligations; and
- whether an interview or job offer has been arranged
SixteenFifty’s current retention notice is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. SixteenFifty will usually inform you (before collecting your data) if they intend to use your data for such purposes or if they intend to disclose your information to any third party for such purposes and will collect express consent from you if legally required prior to using your personal data for marketing purposes. You can exercise your right to prevent such processing by contacting them at firstname.lastname@example.org
Your rights. How you can access, correct and delete your personal information
Under GDPR, you have the following rights:
- Right to access and obtain a copy of your personal information: You are entitled to request confirmation of whether any of your personal information is processed. You may have access to your personal information and to certain information about how it is processed. In some cases, you can ask SixteenFifty to provide you with an electronic copy of your information
- Right to correct your personal information: If you can demonstrate that personal information held about you is incorrect, you can ask that this information is updated or otherwise corrected
- Right to be forgotten/have data deleted: This enables you to ask SixteenFifty to delete or remove personal information where there is no good reason for them continuing to process it. You also have the right to ask SixteenFifty to delete or remove your personal information where you have exercised your right to object to processing.
- 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. It is encouraged you to contact SixteenFifty to ensure your data is accurate and complete. A subject access request should be submitted to email@example.com
Changes to this privacy notice
Any changes SixteenFifty makes to this privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org