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Policies and Procedures

DATA PROTECTION POLICY

April 2018 / Version 1
All organisations that process personal data are required to comply with data protection legislation. This includes in particular the Data Protection Act 2018 and the EU General Data Protection Regulation (together the ‘Data Protection Laws’). The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data.
As a recruitment business the Company collects and processes both personal data and sensitive personal data. It is required to do so to comply with other legislation. It is also required to keep this data for different periods depending on the nature of the data.
This policy sets out how the Company implements the Data Protection Laws. It should be read in conjunction with the Data Protection Procedure.

In this policy the following terms have the following meanings:
‘consent’ means any freely given, specific, informed and unambiguous indication of an individual’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of persona data relating to him or her;
‘data controller’ means an individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data;
‘data processor’ means an individual or organisation which processes personal data on behalf of the data controller;
‘personal data’* means any information relating to an individual who can be identified, such as by a name, an
identification number, location data, an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that natural person.
‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data;
‘processing’ means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to an individual without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable individual;
‘sensitive personal data’* means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data
concerning health, an individual’s sex life or sexual orientation and an individual’s criminal convictions. [Note 1]* For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’ except where we specifically need to refer to sensitive personal data.
data protection policy
‘Supervisory authority’ means an independent public authority which is responsible for monitoring the
application of data protection. In the UK the supervisory authority is ICO.
The Company processes personal data in relation to its own staff, work-seekers and individual client contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is 0661 0875.
The Company may hold personal data on individuals for the following purposes:
• Staff administration;
• Advertising, marketing and public relations
• Accounts and records;
• Administration and processing of work-seekers’ personal data for the purposes of providing work-finding
services, including processing using software solution providers and back office support.
• Administration and processing of clients’ personal data for the purposes of supplying/introducing work-seekers
1. The data protection principles
The Data Protection Laws require the Company acting as either data controller or data processor to process data in accordance with the principles of data protection. These require that personal data is:
1. Processed lawfully, fairly and in a transparent manner;
2. Collected for specified and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. Accurate and kept up to date; every reasonable step must be taken to ensure that personal data that are
inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. Kept for no longer than is necessary for the purposes for which the personal data are processed;
6. Processed in a manner that ensures appropriate security of the personal data, including protection against
unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate
technical or organisational measures; and that
7. The data controller shall be responsible for, and be able to demonstrate, compliance with the principles.
2. Legal bases for processing
The Company will only process personal data where it has a legal basis for doing so (see Annex A). Where the
Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws.
The Company will review the personal data it holds on a regular basis to ensure it is being lawfully processed and it is accurate, relevant and up to date and those people listed in the Appendix shall be responsible for doing this.
Before transferring personal data to any third party (such as past, current or prospective employers, suppliers,
customers and clients, intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support)), the Company will establish that it has a legal reason for making the transfer.
3. Privacy by design and by default
The Company has implemented measures and procedures that adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities. This includes implementing measures such as:
• data minimisation (i.e. not keeping data for longer than is necessary);
• pseudonymisation;
• anonymization
• cyber security
For further information please refer to the Company’s Information Security Policy.
The Company shall provide any information relating to data processing to an individual in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. The Company may provide this information orally if requested to do so by the individual.
1. Privacy notices
Where the Company collects personal data from the individual, the Company will give the individual a privacy notice
at the time when it first obtains the personal data.
Where the Company collects personal data other than from the individual directly, it will give the individual a privacy notice within a reasonable period after obtaining the personal data, but at the latest within one month. If the Company intends to disclose the personal data to a third party then the privacy notice will be issued when the personal data are first disclosed (if not issued sooner).
Where the Company intends to further process the personal data for a purpose other than that for which the data was initially collected, the Company will give the individual information on that other purpose and any relevant further information before it does the further processing.
2. Subject access requests
The individual is entitled to access their personal data on request from the data controller.
3. Rectification
The individual or another data controller at the individual’s request, has the right to ask the Company to rectify any inaccurate or incomplete personal data concerning an individual. If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to rectify the personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those
third parties to ensure that the rectification has occurred.
4. Erasure
The individual or another data controller at the individual’s request, has the right to ask the Company to erase an individual’s personal data. If the Company receives a request to erase it will ask the individual if s/he wants his personal data to be removed entirely or whether s/he is happy for his or her details to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). The Company cannot keep a record of individuals whose data it has erased so the individual may be contacted again by the Company should the Company come into possession of the individual’s personal data at a later date. If the Company has made the data public, it shall take reasonable steps to inform other data controllers and data processors processing the personal data to erase the personal data, taking into account available technology and the cost of implementation. If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to erase the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.
5. Restriction of processing
The individual or a data controller at the individual’s request, has the right to ask the Company to restrict its
processing of an individual’s personal data where:
• The individual challenges the accuracy of the personal data;
• The processing is unlawful and the individual opposes its erasure;
• The Company no longer needs the personal data for the purposes of the processing, but the personal data is required for the establishment, exercise or defence of legal claims; or
• The individual has objected to processing (on the grounds of a public interest or legitimate interest) pending the verification whether the legitimate grounds of the Company override those of the individual.
If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to restrict the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.
6. Data portability
The individual shall have the right to receive personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller in circumstances where:
• The processing is based on the individual’s consent or a contract; and
• The processing is carried out by automated means.
Where feasible, the Company will send the personal data to a named third party on the individual’s request.
7. Object to processing
The individual has the right to object to their personal data being processed based on a public interest or a
legitimate interest. The individual will also be able to object to the profiling of their data based on a public interest or a legitimate interest.
The Company shall cease processing unless it has compelling legitimate grounds to continue to process the personal data which override the individual’s interests, rights and freedoms or for the establishment, exercise or defence of legal claims. The individual has the right to object to their personal data for direct marketing.
8. Enforcement of rights
All requests regarding individual rights should be sent to the person whose details are listed in the Appendix.
The Company shall act upon any subject access request, or any request relating to rectification, erasure, restriction, data portability or objection or automated decision making processes or profiling within one month of receipt of the request. The Company may extend this period for two further months where necessary, taking into account the complexity and the number of requests. Where the Company considers that a request under this section is manifestly unfounded or excessive due to the request’s repetitive nature the Company may either refuse to act on the request or may charge a reasonable fee taking into account the administrative costs involved.
9. Automated decision making
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.
The Company will not carry out any automated decision-making or profiling using the personal data of a child.
Reporting personal data breaches
All data breaches should be referred to the persons whose details are listed in the Appendix.
1. Personal data breaches where the Company is the data controller:
Where the Company establishes that a personal data breach has taken place, the Company will take steps to contain and recover the breach. Where a personal data breach is likely to result in a risk to the rights and freedoms of any individual the Company will notify the ICO.
Where the personal data breach happens outside the UK, the Company shall alert the relevant supervisory authority for data breaches in the effected jurisdiction.
2. Personal data breaches where the Company is the data processor:
The Company will alert the relevant data controller as to the personal data breach as soon as they are aware of the breach.
3. Communicating personal data breaches to individuals
Where the Company has identified a personal data breach resulting in a high risk to the rights and freedoms of any individual, the Company shall tell all affected individuals without undue delay.
The Company will not be required to tell individuals about the personal data breach where:
• The Company has implemented appropriate technical and organisational protection measures to the
personal data affected by the breach, in particular to make the personal data unintelligible to any person
who is not authorised to access it, such as encryption.
• The Company has taken subsequent measures which ensure that the high risk to the rights and freedoms of
the individual is no longer likely to materialise.
• It would involve disproportionate effort to tell all affected individuals. Instead, the Company shall make a
public communication or similar measure to tell all affected individuals.
All individuals have the following rights under the Human Rights Act 1998 (HRA) and in dealing with personal data these should be respected at all times:
• Right to respect for private and family life (Article 8).
• Freedom of thought, belief and religion (Article 9).
• Freedom of expression (Article 10).
• Freedom of assembly and association (Article 11).
Protection from discrimination in respect of rights and freedoms under the HRA (Article 14).
If you have a complaint or suggestion about the Company’s handling of personal data then please contact the person whose details are listed in the Appendix to this policy.
Alternatively you can contact the ICO directly on 0303 123 1113 or at https://ico.org.uk/global/contact-us/email/

List names of those responsible for:
• Rebecca Richardson, Jacquie Bamber -Jones, Mark Bamber, Danielle Hubbard, Kimberley Moey, Katie Green, Ben Hawke, Kirra Graham, Kirsty Hollands, Brandon Dennis, Vicki Jefferies, Harrison Bamber-Jones, Fiona Burgess and Jenna Latino are responsible adding, amending or deleting personal data;
• Rebecca Richardson and Kimberley Moey are responsible for responding to subject access requests/requests for rectification, erasure, restriction data portability, objection, automated decision making processes and profiling and withdrawal of consent;
• Rebecca Richardson and Kimberley Moey are responsible reporting data breaches/dealing with complaints;
a) The lawfulness of processing conditions for personal data are:
1. Consent of the individual for one or more specific purposes.
2. Processing is necessary for the performance of a contract with the individual or in order to take steps at the
request of the individual to enter into a contract.
3. Processing is necessary for compliance with a legal obligation that the controller is subject to.
4. Processing is necessary to protect the vital interests of the individual or another person.
5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of
official authority vested in the data controller.
6. Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party,
except where such interests are overridden by the interests or fundamental rights or freedoms of the
individual which require protection of personal data, in particular where the individual is a child.
b) The lawfulness of processing conditions for sensitive personal data are:
1. Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.
2. Processing is necessary for carrying out data controller’s obligations under employment, social security or
social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental
rights and interests of the individual.
3. Processing is necessary to protect the vital interests of the individual or another individual where the
individual is physically or legally incapable of giving consent.
4. In the course of its legitimate activities, processing is carried out with appropriate safeguards by a
foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade
union aim and on condition that the processing relates only to members or former members (or those who
have regular contact with it in connection with those purposes) and provided there is no disclosure to a third
party without the consent of the individual.
5. Processing relates to personal data which are manifestly made public by the individual.
6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are
acting in their judicial capacity.
7. Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law
which shall be proportionate to the aim pursued, respects the essence of the right to data protection and
provide for suitable and specific measures to safeguard the fundamental rights and interests of the
individual.
8. Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a
contract with a health professional and subject to the necessary conditions and safeguards.
9. Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.

DATA PROTECTION PROCEDURE 

April 2018 / Version 1
All organisations that process personal data are required to comply with data protection legislation. This includes in particular the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together the ‘Data Protection Laws’). The Data Protection Laws give individuals certain rights over their personal data whilst imposing certain obligations on the organisations that process their data.
As a recruitment business the Company collects and processes both personal data and sensitive personal data. It is required to do so to comply with other legislation. It is also required to keep this data for different periods depending on the nature of the data.
This policy sets out the Company’s procedures for implementing the Data Protection Laws. It should be read in conjunction with the REC’s model Data Protection Policy.
In this policy the following terms have the following meanings:
‘consent’ means any freely given, specific, informed and unambiguous indication of an individual’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of persona data relating to him or her;
‘data controller’ means an individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data;
‘data processor’ means an individual or organisation which processes personal data on behalf of the data controller;
‘personal data’* means any information relating to an individual who can be identified, such as by a name, an
identification number, location data, an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that natural person.
‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data;
‘processing’ means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to an individual without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable individual;
‘sensitive personal data’* means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data
concerning health, an individual’s sex life or sexual orientation and an individual’s criminal convictions.
* For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’ except where we need to refer to sensitive personal data specifically.
‘supervisory authority’ means an independent public authority which is responsible for monitoring the
application of data protection. In the UK the supervisory authority is the Information Commissioner’s Office (ICO).
All of these definitions are italicised throughout this policy to remind the reader that they are defined terms
The Company processes personal data in relation to its own staff, work-seekers and individual client contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is 0661 0875.
The Company may hold personal data on individuals for the following purposes:
• Staff administration;
• Advertising, marketing and public relations please refer to our marketing policy;
• Accounts and records;
• Administration and processing of work-seekers’ personal data for the purposes of providing work-finding
services, including processing using software solution providers and back office support.
• Administration and processing of clients’ personal data for the purposes of supplying/introducing work-seekers
• The Company will only process personal data where it has a legal basis for doing so (see Annex A). Where the Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws. 
Only those listed in the Appendix are permitted to add, amend or delete personal data from the Company’s
database(s) (‘database’ includes paper records or records stored electronically).
All Company staff are responsible for notifying those listed in the Appendix where information is known to be old, inaccurate or out of date or a request for erasure, access, rectification or restriction of processing has been received
from the individual. Company staff are also responsible for notifying those listed in the Appendix where any request
for data portability, objection to processing or where consent to process has been withdrawn and has been received from the individual.
The incorrect processing of personal data e.g. sending an individual’s details to the wrong person, allowing
unauthorised persons access to personal data, sending information out for purposes for which the individual did not give their consent, or not having a lawful reason to process personal data, may give rise to a breach of contract and/or negligence leading to a claim against the Company for damages from an employee, work-seeker or client contact.
A failure to observe the contents of this procedure policy will be treated as a disciplinary offence.
In addition all Company staff should ensure that adequate security measures are in place to limit the risk of personal data breaches. For example:
• Staff should lock their computer screens when they are not in use.
• All devices, whether company or personal devices (including but not limited to computers, mobile phones, other hand-held devices) containing personal data relating to the services of the Company shall be encrypted and password protected.
• Staff should not disclose their passwords to anyone.
• Email should be used with care. Company staff must ensure that emails are sent only to the intended recipient/s. Where Company staff send an email in error then the email must be recalled immediately and Company staff must inform those listed in the Appendix of the error so that any risk of a personal data breach can be limited.
• Personnel files (whether for internal staff or work-seekers) and other personal data should be stored securely to prevent unauthorised access. They should not be removed from their usual place of storage without good reason.
• Personnel files (whether for internal staff or work-seekers) should always be locked away when not in use and when in use should not be left unattended.
• Personal data should only be stored for the periods set out in the Company’s data retention policy.
• Processing includes the destruction or disposal of personal data. Therefore staff should take care to destroy or dispose of personal data safely and securely. Such material should be shredded or stored as confidential waste awaiting safe destruction.
An individual has the following rights under the Data Protection Laws:
1. The right to be informed of what information the Company holds on them – this is typically given to the
individual in a privacy notice;
2. The right of access to any personal data that the Company holds on them – this is usually referred to as a
‘subject access request’;
3. The right to rectification of personal data that the individual believes is either inaccurate or incomplete;
4. The right to erasure of their personal data in certain circumstances;
5. The right to restrict processing of their personal data;
6. The right to data portability of their personal data in specific circumstances;
7. The right to object to the processing of their personal data where it is based on either a legitimate interest or a public interest;
8. The right not to be subjected to automated decision making and profiling; and
9. The right to withdraw consent where it was relied upon to process their personal data.

1. The right to be informed
Any individual whose personal data is processed by the Company will have the right to be informed about such processing. They will have the right to be informed about who, what, where and why the data is processed. This information should be delivered in a privacy notice, in writing and where appropriate electronically. Depending on where the personal data are being collected, an individual may be directed to the Company’s website privacy notice or be given a copy of a privacy notice. This privacy notice should be issued in instances where either:
a) the Company collects/processes data directly from the individual; or
b) the Company has not collected/processed the data from the individual directly.
The privacy notice should include the information set out in Table 1 (below).
In addition:
a) Where personal data has been collected from the individual the privacy notice will need to be issued at the
point the data is collected. Where the Company intends to further process the personal data for a purpose other than that for which the personal data was collected, the Company shall provide the individual, prior to that further processing, with information on that other purpose and with any relevant further information in updated privacy notice.
b) Where personal data has not been obtained from the individual, the Company shall provide the privacy notice within a reasonable period after obtaining the personal data, but at the latest within one month, having regard to the specific circumstances in which the personal data are processed. If the personal data are to be used to communicate with the individual then the privacy notice will be issued at the time of the first communication with the individual. If a disclosure to another recipient is envisaged, then the privacy notice will be issued to the individual at the latest when the personal data are first disclosed.
Company staff will be responsible for issuing privacy notices to individuals whose personal data is processed by the Company in the timeframes and circumstances mentioned above.

 

   Where the Company
collects data from
the individual:
 Where personal data
has not been
obtained from the
individual:
 • The identity and contact details of the Company and where
applicable the controller’s representatives and/or data
protection officer.
 YES (Y)  Y
 • The purposes of processing and the legal basis for the
processing.
 Y  Y 
 • The legitimate interest of the data controller or third party, where applicable.  Y  Y
• The categories of personal data.  NO(N)   Y 
 • Recipients or categories of recipients of personal data.  Y  Y 
 • Details of transfers to third countries and the safeguards in
place.
 Y  Y
 • The retention period of the data or the criteria used to
determine the retention period.
 Y  Y
 • The existence of individual’s rights including the right of
access, rectification, erasure, restriction of processing, objection to processing and the right to data portability.
 Y  Y
 • The existence of the right to withdraw consent where it has
been given and relied upon.
 Y  Y
 • The right to lodge a complaint with the Information
Commissioner’s Office or any other relevant supervisory authority.
 Y  Y
 • The source the personal data originates from and whether it came from publicly accessible sources.  N  Y
 • Whether the provision of personal data form part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data.  Y  N
 • The existence of automated decision-making, including profiling and information about how decisions are made, the significance and the consequences.  Y  Y


2. The right to access (‘subject access request’)
Individuals are entitled to obtain access to their personal data on request, free of charge except in certain
circumstances.
An individual will be entitled to the following information:
• Confirmation that their personal data is or is not being processed;
• Access to the personal data undergoing processing;
• The purposes of the processing;
• The categories of personal data concerned;
• The recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• The existence of the right to request from the Company rectification or erasure of personal data or restriction of processing of personal data concerning the individual or to object to such processing;
• The right to lodge a complaint with the ICO or any other relevant supervisory authority;
• Where the personal data are not collected from an individual, any available information as to the source of that information;
• The existence of automated decision-making, including profiling, based on a public interest or a legitimate
interest and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the individual. If the Company transfers the individual’s personal data to a third country or to an international organisation, the  individual shall have the right to be informed of the appropriate safeguards in place relating to the transfer.
If the Company processes a large quantity of information concerning the individual making the request, the
Company might request that the individual specify the information or processing activities to which the request relates to specifically before the information is delivered. If such a request is required by the Company then it shall be delivered promptly to the individual, taking into consideration the timeframes that subject access requests must be completed.
The individual’s right to access their information shall not adversely affect the rights and freedoms of others and they will not be able to access the personal data of third parties without the explicit consent of that third party or if it is reasonable in all the circumstances to comply with the request without that third party’s consent, taking into consideration any means to redact the personal data of any third party. Persons listed in the Appendix will decide whether it is appropriate to disclose the information to the individual on a case by case basis. This decision will involve balancing the individual’s right of access of their personal data against the third party’s rights in respect of their own personal data.
Note : An individual might not label their subject access request as such. Therefore Company staff should always consider whether a request is a subject access request even when not called that. If in doubt, refer to the persons listed in the Appendix.
The right to rectification
An individual, or another data controller acting on an individual’s behalf, has the right to obtain from the Company rectification of inaccurate or incomplete personal data concerning him or her. The Company must act on this request without undue delay.
Taking into account the purposes of the processing, the individual shall have the right to have incomplete personal
data completed, including by means of providing a supplementary statement stating what they would require to be completed.
The Company shall communicate any rectification of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Company shall inform the individual about those recipients if he or she requests it.
Where the Company, acting as a data processor, receives information from a data controller to rectify an individual’s personal data, then the Company shall comply with this request unless this proves impossible or involves disproportionate effort.
In circumstances where the Company is unable to comply with the request as it proves impossible or involves
disproportionate effort, the Company will document this in a privacy impact assessment or similar.

3. The right to erasure (‘right to be forgotten’)
An individual shall have the right to obtain from the Company, acting as data controller, the erasure of personal data concerning him or her without undue delay. The Company will be obliged to erase the individual’s personal data without undue delay where one of the following grounds apply:
• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• An individual withdraws consent on which the processing is based, and where there is no other legal ground for the processing;
• An individual objects to the processing (based on either a public interest or a legitimate interest) and there are no overriding legitimate grounds for the processing, or an individual objects to the processing for direct
marketing purposes (including profiling related to direct marketing);
• The personal data have been unlawfully processed;
• The personal data have to be erased for compliance with a legal obligation; or
• The personal data have been collected in relation to the offer of information society services to a child.
Where the Company, acting as data controller, has made the personal data public and is obliged to erase that
personal data, the Company, taking into account available technology and the cost of implementation, shall take reasonable steps, including technological measures, to inform data controllers which are processing the personal data that an individual has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
The Company will not be obliged to erase information to the extent that processing is necessary:
• For exercising the right of freedom of expression and information;
• For compliance with a legal obligation which requires processing, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Company acting as controller;
• For reasons of public interest in the area of public health;
• For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
• For the establishment, exercise or defence of legal claims.
The Company shall communicate any erasure of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Company shall inform the individual about those recipients if an individual requests it.
Where the Company, acting as a data processor, receives information from a data controller to erase an individual’s personal data the Company shall comply with this request, unless this proves impossible or involves disproportionate effort.
In circumstances where the Company is unable to comply with the request as it proves impossible or involves
disproportionate effort, the Company will document this in a privacy impact assessment or similar.

4. The right to restrict processing
An individual will have the right to obtain from the Company, acting as a data controller, the restriction of processing his or her personal data where one of the following applies:
• The accuracy of the personal data is contested by the individual, for a period enabling the Company to verify the accuracy of the personal data;
• The processing is unlawful and the individual opposes the erasure of the personal data and requests the
restriction of their use instead;
• The Company no longer needs the personal data for the purposes of the processing, but they are required by an individual for the establishment, exercise or defence of legal claims;
• The individual has objected to processing (on the grounds of a public interest or legitimate interest) pending the verification whether the legitimate grounds of the Company override those of the individual.
Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the individual’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.
Where an individual who has successfully asked for their personal data to be restricted, then the Company will
inform the individual before such a restriction is lifted.
The Company shall communicate any restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Company shall inform the individual about those recipients if he or she requests it.
Where the Company, acting as a data processor, receives information from a data controller to restrict processing an individual’s personal data, the Company shall comply with this request, unless this proves impossible or involves disproportionate effort.
In circumstances where the Company is unable to comply with the request as it proves impossible or involves
disproportionate effort, the Company will document this in a privacy impact assessment or similar.

5. The right to data portability

An individual has the right to receive any personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller where:
• The processing is based on the individual’s consent or a contract; and
• The processing is carried out by automated means.
•Company staff will advise those listed in the Appendix when they receive a request to port data. Those listed in the Appendix will be responsible for identifying if the above circumstances are satisfied for the purposes of porting the data to the individual and/or another data controller.
For the avoidance of doubt, there is no obligation to port personal data that is not kept by automated means by the Company.

6. The right to object to processing
An individual, has the right to object to their personal data being processed or profiled based on a public interest or a legitimate interest.
Where the Company receives an objection to processing or profiling on the above, those listed in the Appendix will ensure that the processing and/or profiling ceases unless such persons can establish compelling grounds to continue to process the personal data. If this is the case those persons listed in the Appendix will document this in a privacy impact assessment or similar.

7. Automated decision making processes
An individual has the right not to be subjected to an automated decision making process, including profiling, that produces a legal effect or a similarly significant effect on the individual.
However, it is possible to subject an individual to automated decision making processes, including profiling, where:
a) It is necessary for entering into or performance of a contract between the employer and the individual;
b) It is authorised by law; or
c) The individual has given their explicit consent.
Where a) and c) apply the Company will ensure that suitable measures are in place to safeguard the individual’s rights and freedoms and legitimate interests, under both Data Protection Laws and the Human Rights Act 1998, before this type of processing occurs for personal data.
Where a) to c) apply the Company will only process sensitive personal data where the Company has received either the explicit consent to do so or there is a substantial public interest to do so. Again the Company will ensure that suitable measures are in place to safeguard the individual’s rights and freedoms and legitimate interests, under both Data Protection Laws and the Human Rights Act 1998, before this type of processing occurs for sensitive personal data. The safeguarding measures include:
• [Conducting a risk assessment as to what risks are posed to the individual’s rights and freedoms];
• [Ensuring where the automated decision making process is necessary for entering into or performance of a
contract, that this is documented clearly by the Company];
• [Ensuring where explicit consent is given this is documented clearly by the Company]
Company staff will be responsible for implementing the above safeguarding measures.

8. The right to withdraw consent

Where the Company relies on an individual’s consent to process their personal data then the Company will advise the individual that they have the right to withdraw his or her consent at any time.
Any Company staff who receives a request from an individual to withdraw their consent to processing their data will be responsible for issuing the individual with the Company’s withdrawal of consent form. Once the form has been completed it should be given to the persons listed in the Appendix to process the individual’s request further.

9. Timing and information to be provided to the individual

The Company shall provide information on action taken or not taken with regards to the individual data protection rights, set out in paragraphs 1 to 9 inclusive, without undue delay and in any event within one month of receipt of the request. Where the Company does take action, then it may, where necessary, extend this period by a further two months, taking into account the complexity and number of the requests. Those persons listed in the Appendix shall inform an individual of any extension within one month of receipt of the request, together with the reasons for the delay. Where the Company does not take action on the request of the individual then those persons listed in the
Appendix will inform him or her on the possibility of lodging a complaint with the ICO and seeking a judicial remedy.

10. Charges
Where requests from an individual are manifestly unfounded or excessive, in particular because of their repetitive character, the Company may either:
• Charge a reasonable fee taking into account the administrative costs of providing the information or
communication or taking the action requested; or
• Refuse to act on the request.
The Company must demonstrate whether the request is manifestly unfounded or excessive. Those listed in the Appendix will be responsible for demonstrating this.
Where the individual makes the request by electronic means the Company shall provide the information in a
commonly used electronic form, unless otherwise requested by the individual.
The Company will need to act on any personal data protection breach it suspects or knows of when acting as either a data controller or a data processor. Company staff must inform those persons listed in the Appendix where a personal data breach has either been reported to him or her or they themselves have identified a personal data breach.
1. Personal data breaches where the Company is the data controller:
Those listed in the Appendix will take measures to establish whether or not a personal data breach has occurred.
Those persons will:
• [Conduct a risk assessment as to what level of risk the personal data breach poses/has occurred];
• [Conduct any relevant interviews or investigations of the Company’s practices and/or Company staff to assess how the personal data breach occurred]
• [Implement measures and take steps to limit, contain and recover the breach]
Unless the personal data breach is unlikely to result in a risk to the rights and freedoms of an individual, then those listed in the Appendix will be responsible for alerting the ICO of any personal data breach without undue delay, but no later than 72 hours after having become aware of the Company’s personal data breach. Where it is not possible to inform the ICO in this time those listed in the Appendix will be responsible for explaining to the ICO the reasons for the delay.
If the personal data breach happens outside the UK then those listed in the Appendix will be responsible for alerting the relevant supervisory authority in the effected jurisdiction.
If those listed in the Appendix are not able to provide the ICO/other relevant supervisory authority with all the
relevant information related to the personal data breach then those persons shall provide the information in phases without undue further delay.
Those listed in the Appendix will be responsible for documenting any personal data breaches, including:
• The facts relating to the personal data breach – including any investigations undertaken or statements taken from the Company’s staff;
• The effects of the personal data breach; and
• The remedial action taken.
2.Personal data breaches where the Company is the data processor:
Those listed in the Appendix will be responsible for alerting the relevant data controller as to the personal data breach that has been identified as soon as they are aware of the breach, having particular regard to any contractual obligations the Company has with the data controller.
3.Communicating personal data breaches to individuals
Where a personal data breach has been identified, which results in a high risk to the rights and freedoms of
individuals, those listed in the Appendix will be responsible for informing those individuals effected by the personal data breach without undue delay.
For the avoidance of doubt there will be no need to inform individuals of a personal data breach where:
• The Company has implemented appropriate technical and organisational protection measures to use the
personal data affected by the breach, in particular to make the personal data unintelligible to any person
who is not authorised to access it, such as encryption.
• The Company has taken subsequent measures which ensure that the high risk to the rights and freedoms of
the individual is no longer likely to materialise.
It would involve disproportionate effort to tell all affected individuals. Instead, those listed in the Appendix shall, on behalf of the Company, make a public communication or similar measure to tell all affected individuals.



Those listed in the Appendix will keep written records of the processing activities of the Company. The records must be in writing (which can be in electronic form) and must include the following information:
• The name and contact details of the data controller or data controller’s representative and any joint
controllers;
• The purposes of the processing;
• A description of the categories of the data subjects and of the categories of the personal data;
• The categories of recipients to whom personal data have or will be disclosed to, including to those
internationally;
• Any transfers of personal data internationally, including the identification of the third country or
international organisation to which the data is transferred;
• The envisaged time limits placed on an individual’s right to erasure; and
• Where possible, a description of the technical and security measures that have been utilised to alleviate
data-related risks.
The Company will also document:
• Information required for privacy notices;
• Records of consent;
• Controller-processor contracts;
• The location of personal data;
• Data Protection Impact Assessment reports;
• Records of personal data breaches;
• Information required for processing sensitive personal data or criminal convictions/offences data.
• The Company will make these records available to the ICO upon request.
Where Company staff receive a complaint from an individual about the use of his or her personal data then they should bring this to the immediate attention of those listed in the Appendix.
List names of those responsible for:
• Rebecca Richardson, Jacquie Bamber -Jones, Mark Bamber, Danielle Hubbard, Kimberley Moey, Katie Green, Ben Hawke, Annie Kent, Kirsty Hollands, Anthony Geach, Claire Maddox, Harrison Bamber-Jones, Fiona Burgess and Jenna Latino are responsible adding, amending or deleting personal data;
• Rebecca Richardson and Kimberley Moey are responsible for responding to subject access requests/requests for rectification, erasure, restriction data portability, objection, automated decision making processes and profiling and withdrawal of consent;
• Rebecca Richardson and Kimberley Moey are responsible reporting data breaches/dealing with complaints;
a) The lawfulness of processing conditions for personal data are:
1. Consent of the individual for one or more specific purposes.
2. Processing is necessary for the performance of a contract with the individual or in order to take steps at the
request of the individual to enter into a contract.
3. Processing is necessary for compliance with a legal obligation to which the controller is subject to.
4. Processing is necessary to protect the vital interests of the individual or another person.
5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of
official authority vested in the data controller.
6. Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party,
except where such interests are overridden by the interests or fundamental rights or freedoms of the
individual which require protection of personal data, in particular where the individual is a child.
b) The lawfulness of processing conditions for sensitive personal data are:
1. Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.
2. Processing is necessary for carrying out data controller’s obligations under employment, social security or
social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental
rights and interests of the individual.
3. Processing is necessary to protect the vital interests of the individual or another individual where the
individual is physically or legally incapable of giving consent.
4. In the course of its legitimate activities, processing is carried out with appropriate safeguards by a
foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade
union aim and on condition that the processing relates only to members or former members (or those who
have regular contact with it in connection with those purposes) and provided there is no disclosure to a third
party without the consent of the individual.
5. Processing relates to personal data which are manifestly made public by the individual.
6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are
acting in their judicial capacity.
7. Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law
which shall be proportionate to the aim pursued, respects the essence of the right to data protection and
provide for suitable and specific measures to safeguard the fundamental rights and interests of the
individual.
8. Processing is necessary for the purposes of preventative or occupational medicine, for assessing the workingcapacity of the employee, medical diagnosis, the provision of health or social care or treatment or the
management of health or social care systems and services on the basis of EU or Member State law or a
contract with a health professional and subject to the necessary conditions and safeguards.
9. Processing is necessary for reasons of public interest in the area of public health, such as protecting againstserious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.

PRIVACY NOTICE-WHEN DATA IS NOT OBTAINED FROM DATA SUBJECT 

April 2018 / Version 1
The Company 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.
You may give your personal details to the Company 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. 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. Collection and use of personal data
a. Purpose of processing and legal basis
The Company has collected 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:

  • Consent
  • Legitimate interest
  • Legal obligation
  • Contractual obligation

b. Categories of data
The Company has collected the following personal data on you:
Personal data:

  •  Name/contact details

c. Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

  • Processing data for direct marketing purposes or preventing fraud
  • Transmission of personal data for an internal administrative purpose including client and employee data.
  • Reporting possible criminal acts or threats to public security to a competent authority.

d. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:

  • Clients
  • Profile, Merit, Sage, NEST and HSBC Bank
  • Third parties communication as requested by our clients- Depole, Venneu, 247, Ariba, Comensura, Jobline Staffing, Tradeshift and Coupa
  • HMRC , DWP, CSA, HM courts and other government bodies
  • Atlantic data, Disclosure & baring service ( DBS) , Disclosure Scotland or AcessNI – if a DBS check needs to be carried out for a role
  • DVLA – if a check needs to be carried out for a role

2. 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 retention 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.
3. 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 contacting Rebecca Richardson and Kimberley Moey.
4. Source of the personal data
The Company sourced your personal data/sensitive personal data by the following means:

  • Indeed/ Proper Jobs or another job board
  • Facebook/ Twitter

This information did not come from a publicly accessible source.
5. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Rebecca Richardson and Kimberley Moey

 

Gender Pay Gap Report 2016-17

 

As Smith & Reed Recruitment (SW) Limited employs more than 250 people, we are required by law to report on our Gender Pay Gap.  The results from this report are published on our website and submitted to the Government;

https://gender-pay-gap.service.gov.uk/viewing/employer-details?id=RiLpaGqX-5L9vStA7-PW6w%21%21

These statistics below are presented at the snapshot date of 5th April 2017.

Difference In Hourly Rates

 

Mean Gap

The mean hourly rate is the average hourly wage across the entire company.  The mean gender pay gap is a measure of the difference between women’s mean hourly wage and men’s hourly wage.

Our Mean Gap = -4.4% (women’s mean hourly rate is 4.4% higher than men’s)

   

Median Gap

The median hourly rate is calculated by ranking all employees from the highest paid to the lowest paid and taking the hourly wage of the person in the middle.  The median gender pay gap is the difference between women’s median hourly wage (middle paid woman) and men’s median hourly wage (middle paid man).

Our Median Gap = -3.6% (women’s median hourly rate is 3.6% higher than men’s) 

In other words, when comparing mean & median hourly rates, women earn £1.04 for every £1 that men earn.

Proportion Of Woman In Each Pay Quartile

Pay quartiles are calculated by splitting all employees in an organisation into four even groups according to their level of pay.  Looking at the proportion of women in each quartile gives an indication of women’s representation at different levels of the organisation.

Pay quartile analysis shows that there is a gender pay gap in each quartile in favour of women, except for the lower middle quartile with a 50/50 split.

 

Who Received Bonus Pay

3.7% of women

1.5% of men

 

Difference in Bonus Pay

-        Women’s mean bonus pay is 2.1% higher than men’s

-        Women’s median bonus pay is 86.9% higher than men’s

Declaration:
We confirm that Smith & Reed Recruitment (SW) Ltd’s pay gap data has been collected and presented within this report in accordance with the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017

AJ Geach
Financial Controller

 

 

 

PRIVACY NOTICE

 

  May 2018 / Version 1
Company contact details: Rebecca Richardson & Kimberley Moey
The Company 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.

You may give your personal details to the Company 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. 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 this privacy statement. At all times we will comply with current data protection laws.
Contents
1.       Collection and use of personal data
a.       Purpose of processing and legal basis
b.      Legitimate interest
c.       Statutory/contractual requirement
d.      Recipients of data

2.       Information to be provided when data is not collected directly from the data subject
a.       Categories of data
b.      Sources of data

3.       Overseas transfers

4.       Data retention

 5.       Your rights

 6.       Automated decision making

 7.       Cookies

 8.       Login files

 9.       Links to external sites

 10.   Sale of the business

 11.   Data security

 12.   Changes to this privacy statement

 13.   Complaints or queries

 

 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. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you 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 emailing us, when you receive these communications]

 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:
·                     Your consent
·                     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 the Company 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 the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
a.       Managing our database and keeping work-seeker records up to date;
b.      Providing work-finding services to you and our clients;
c.       Contacting you to seek your consent where we need it;
d.      Giving you information about similar services that you have used from us recently;

 c. Statutory/contractual requirement

 The Company 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. Recipient/s of data
The Company 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
·         Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we          may introduce you to
·         DVLA
·         Atlantic data, Disclosure & baring service ( DBS) , Disclosure Scotland or AcessNI – if a DBS check needs          to be carried out for a role
·         HMRC , DWP, CSA, HM courts and other government bodies
·         Profile, Merit, Sage, NEST and HSBC Bank

 Categories of data: The Company has collected the following personal data on you:
Personal data:
·                     Name, address, mobile number email
·                     National insurance number
·                     Nationality (through right to work check)
·                     Bank Account details
·                     Driving licence

 Sensitive personal data:
·                     Health information including whether you have a disability
·                     Criminal conviction
·                     Sexual orientation ( through emergency contact details)
·                     DBS

 Source of the personal data: The Company sourced your personal data/sensitive personal data:
·                    From Our Website, Facebook, LinkedIn, Indeed, Proper Jobs and other job boards
·                    A former employer
·                    A referee whose details you previously provided to us
·                    Software provides who we use to support our services including
·                    Cookies listed in section 7
·                    A friend or family member if they have recommended you

 

 This information came from a publicly accessible source.

 Overseas Transfers

 The Company will not 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. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

 Data retention

 The Company 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 the Company has obtained your consent to process your personal and sensitive personal data we will do so in line with our retention 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.

 

  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 contacting Rebecca Richardson and Kimberley Moey. 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 the Company 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 the Company 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.

 Cookies

 We may obtain data about you from cookies.  These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.

 

 

Cookie

 

Purpose

 

 

 

Google Analytics

 

Web Statistics Tool

 

 

 

GetClicky

 

Web Statistics Tool

 

 

 

Web Statistics Tool

 

Temporary storage for account login

   Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, Please note that in a few cases some of our website features may not function if you remove cookies from your browser.

 Log Files

 We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use.  IP addresses are not linked to personally identifiable information.

 Links to external websites

 The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites.  When you leave our site 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 the Company’s website. 

 Sale of business 

If the Company’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. 

Data Security

The Company takes every precaution to protect our users’ information.  Please refer to our Data protection procedure.

 Only employees who need the information to perform a specific job are granted access to your information.

 

 The Company 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 the Company 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 Rebecca Richarson : rebecca.richardson@smithandreed.co.uk or Kimberley Moey : kim.moey@smithandreed.co.uk

 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.

 Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact Rebecca Richarson : rebecca.richardson@smithandreed.co.uk or Kimberley Moey : kim.moey@smithandreed.co.uk

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.

 

 

 

 

 

Smith & Reed Recruitment is committed to leading the industry in minimising the impact of its activities on the environment.

 

The key points of our strategy to achieve this are:

 

  • Minimise waste by evaluating operations and ensuring they are as efficient as possible.
  • Minimise toxic emission s through the selection and use of its fleet and the source of its power requirement.
  • Actively promote recycling both internally and amongst its customers and suppliers
  • Meet and exceed all the environmental legislation that relates to the company.

 

J Bamber-Jones, Director    January 2013

 

  • ASSISTANT MARINE OPERATIONS MANAGER
    Permanent - Falmouth, Cornwall
    £30-£35k DOE (Full Time)
    Read more
  • IT TRAINER/ACCOUNT MANAGER
    Permanent - South West or Wales
    £24-28,000/Annum
    Read more
  • RETAIL STOCK ASSISTANTS
    Temporary - Newquay, Cornwall
    £7.83 per hour (Between 30-40 per week)
    Read more
  • WAREHOUSE MANAGER
    Permanent - Plymouth, Cornwall
    £22-28,000 Dependent on Experience
    Read more
  • PRODUCTION OPERATIVES/LABOURERS
    Temp to Perm - Redruth, Cornwall
    £7.83/Hour
    Read more
  • WELDER
    Permanent - St Austell, Cornwall
    £10-£13 per hour DOE (Full Time)
    Read more
  • FORKLIFT DRIVER
    Temp to Perm - Penzance, Cornwall
    £7.83 - £8.32 per hour (Full Time)
    Read more
  • ASSISTANT MAINTENANCE MANAGER (GENERAL ENGINEERING)
    Temporary - Falmouth, Cornwall
    £Dependent on Experience (Full time)
    Read more
  • PACKING / ASSEMBLY ASSISTANT
    Temporary - Falmouth, Cornwall
    £8.30 per hour (Monday to Friday)
    Read more
  • MAINTENANCE ELECTRICIAN
    Permanent - Falmouth, Cornwall
    £Dependent on Experience (Full time)
    Read more
  • RECEPTIONIST
    Temporary - Truro, Cornwall
    £7.83 per hour (Flexible)
    Read more
  • ADMINISTRATOR
    Temporary - Redruth, Cornwall
    £8.00 + per hour (Flexible)
    Read more
  • SALES EXECUTIVE
    Permanent - Truro, Cornwall
    £18,000 - £30,000 + Commission (DOE) (Full Time)
    Read more
  • SECRETARY
    Temporary - Truro, Cornwall
    £9.00 + per hour (DOE) (Part time)
    Read more
  • ADMINISTRATOR
    Temp to Perm - Redruth, Cornwall
    £10.25 per hour (Full time)
    Read more
  • WAREHOUSE/FORKLIFT OPERATIVES
    Temporary - Redruth, Cornwall
    £8.80-9.60/Hour Dependent on shift
    Read more
  • DATA ENGINEER
    Permanent - Bodmin, Cornwall
    £18-40,000 Dependent on Experience (Full Time)
    Read more
  • ACCOUNTS ASSISTANT
    Permanent - St Austell, Cornwall
    £8.50 - £9.00 per hour (Part time )
    Read more
  • FISH FILLETER
    Permanent - St Columb, Cornwall
    £9.00 - £14.00 per hour. (Full Time )
    Read more
  • PRODUCTION OPERATIVES
    Temporary - Newquay, Cornwall
    £8.30 per hour (Various shifts available)
    Read more
  • MECHANIC / VEHICLE TECHNICIAN
    Permanent - Truro, Cornwall
    £23000 - £24000 per annum (Full Time )
    Read more
  • WAREHOUSE OPERATIVE
    Temporary - Redruth, Cornwall
    £7.83-£9.66 (Various shifts available)
    Read more
  • PACKING AND PRODUCTION OPERATIVES
    Temporary - Falmouth, Cornwall
    £7.83 per hour (Various shifts available)
    Read more
  • REMOVAL PORTERS
    Temporary - Truro, Cornwall
    £7.83 per hour (Days)
    Read more
  • MANUAL MACHINIST
    Permanent - Bodmin, Cornwall
    £Dependent on Experience (Full Time)
    Read more
  • WAREHOUSE OPERATIVE
    Temporary - Padstow, Cornwall
    £7.83 per hour (Various shifts available)
    Read more
  • SITE OPERATIVES - OUTDOOR WORK
    Temporary - Various locations throughout Cornwall
    £7.38 - £12.58 per hour (09.00-16.00)
    Read more
  • PART TIME WAREHOUSE OPERATIVES
    Temporary - St Austell, Cornwall
    £7.83 per hour (25 hours per week )
    Read more
  • CHEF
    Permanent - Redruth, Cornwall
    £9 per hour (25-30 per week )
    Read more
  • DIGITAL MARKETING EXECUTIVE
    Permanent - Falmouth, Cornwall
    £18-21,000 Dependent on Experience
    Read more
  • CNC FIELD SERVICE ENGINEER
    Permanent - Exeter, Devon
    £35,000-40,000
    Read more
  • FINANCE ASSISTANT
    Permanent - Launceston, Cornwall
    £19,000 (Full time)
    Read more
  • IT TRAINER
    Permanent - Bodmin, Cornwall
    £18-20,000/Annum DoE
    Read more
  • IT INFRASTRUCTURE ENGINEER
    Permanent - Falmouth, Cornwall
    to £34K (Full time)
    Read more
  • TRAINEE FOOD PRODUCTION ASSISTANTS
    Temporary - Bodmin, Cornwall
    £7.83 per hour (0600-1400)
    Read more
  • PACKING AND PRODUCTION ASSISTANTS
    Temporary - St Austell, Cornwall
    £7.83 per hour (09.00 till finish )
    Read more
  • PRODUCTION WORKERS
    Temporary - Bodmin, Cornwall
    £7.83 - £8.20 per hour (Various shifts available)
    Read more
  • CONTRACTS MANAGER
    Permanent - St Austell, Cornwall
    c£40K
    Read more
  • FACTORY & WAREHOUSE ASSISTANTS
    Temporary - Padstow, Cornwall
    £7.83 per hour (Full time, 8 or12 hour shifts)
    Read more
  • DEVELOPMENT AND INTEGRATION ENGINEER
    Permanent - Bodmin, Cornwall
    £28-40,000
    Read more
  • MULTIDROP DRIVERS NEEDED
    Temporary - Redruth, Cornwall
    £8.00 + per hour DOE (Full time)
    Read more
  • PACKING/LABELLING ASSISTANTS
    Temporary - Wadebridge, Cornwall
    £7.83 per hour (Monday - Friday, full time)
    Read more
  • FOOD PRODUCTION OPERATIVES
    Temp to Perm - Padstow, Cornwall
    £7.83 per hour (Various)
    Read more
  • KITCHEN PORTERS
    Temporary - Padstow, Cornwall
    £7.83 per hour + (Various)
    Read more
  • PATISSERIE / BAKERY ASSISTANT
    Temp to Perm - Padstow, Cornwall
    £7.83 per hour (Full time)
    Read more
  • FORKLIFT DRIVERS
    Temporary - Redruth, Cornwall
    £7.83 - £9.30 per hour (Various Shifts)
    Read more
  • FOOD PRODUCTION ASSISTANTS
    Temporary - Penzance, Cornwall
    £7.83 per hour (12 hour shifts)
    Read more
  • WAREHOUSE ASSISTANTS
    Temporary - Liskeard, Cornwall
    £8.00 per hour (Full Time )
    Read more
  • PACKING/PRODUCTION ASSISTANTS
    Temporary - Falmouth, Cornwall
    £7.83 per hour (Full and Part Time )
    Read more
  • SITE OPERATIVES - OUTDOOR WORK
    Temporary - Cornwall
    £7.83 - £12.00 per hour (Various)
    Read more
  • PACKING/PRODUCTION WORKERS
    Temporary - Redruth, Cornwall
    £7.83 per hour (Full time, Monday -Sunday)
    Read more
  • PRODUCTION LINE/WAREHOUSE ASSISTANTS
    Temporary - St Austell, Cornwall
    £7.83 per hour (Various shifts)
    Read more
  • PACKING ASSISTANT
    Temporary - St Austell, Cornwall
    £7.83 per hour (40 hours a week)
    Read more
  • PRODUCTION SUPERVISOR
    Temp to Perm - Penzance, Cornwall
    £22-24,000 (40 Hours/week on a flexible rota)
    Read more
  • FOOD PRODUCTION WORKERS
    Temporary - Bodmin, Cornwall
    £7.83 per hour (Full time, weekdays)
    Read more
  • HYGIENE OPERATIVES
    Temporary - Falmouth, Cornwall
    £7.83 per hour (Various)
    Read more
  • ASSEMBLY OPERATIVES
    Temporary - St Austell, Cornwall
    £7.83 per hour (Monday - Friday, full time)
    Read more
  • PACKING & PRODUCTION WORKERS
    Temp to Perm - Newquay, Cornwall
    £8.30 per hour (Full time - flexible shifts)
    Read more
  • PACKING ASSISTANT
    Temporary - Helston, Cornwall
    £7.83 per hour (09:00-15:00 Monday to Friday)
    Read more
  • BAR AND WAITING STAFF
    Permanent - St. Ives, Cornwall
    £ Dependent on Experience
    Read more
  • FORKLIFT DRIVER AND WAREHOUSE ADMINISTRATOR
    Temp to Perm - Redruth, Cornwall
    £7.90 per hour (40 hours )
    Read more
  • PACKING AND PRODUCTION OPERATIVES
    Temporary - Redruth, Cornwall
    £7.83 per hour (Various shifts available)
    Read more
  • WASTE OPERATIVES
    Temporary - St Austell, Cornwall
    £8.50 per hour (0830-1630)
    Read more
  • PLUMBER
    Temporary - Truro, Cornwall
    £10.50 per hour (Full Time)
    Read more
  • FORKLIFT DRIVER
    Temp to Perm - Redruth, Cornwall
    £8 per hour (Full Time)
    Read more
  • COMMERCIAL FLOOR FITTER
    Permanent - Redruth, Cornwall
    £20k-£30k DOE (Full Time)
    Read more
  • BENCH JOINER
    Permanent - Lostwithiel, Cornwall
    £25k-£30k DOE (Full Time)
    Read more
  • PROJECT MANAGER
    Permanent - Falmouth, Cornwall
    £Negotiable (Full Time)
    Read more
  • CAD TECHNICIAN
    Permanent - Wadebridge, Cornwall
    £23k (Full Time)
    Read more
  • CLEANER
    Permanent - Truro, Cornwall
    £7.83 per hour (Part Time)
    Read more
  • HGV TECHNICIAN/MECHANIC
    Permanent - Redruth, Cornwall
    £34,000 (Full Time)
    Read more
  • SYSTEMS ARCHITECT
    Permanent - Bodmin, Cornwall
    £45-55K
    Read more
  • ACCOUNTANT (AAT QUALIFIED)
    Permanent - St Austell, Cornwall
    c£25,000 (09:00-17:15)
    Read more
  • AGRICULTURAL ENGINEER/TECHNICIAN
    Permanent - Newquay, Cornwall
    £23k plus OT (Full Time)
    Read more
  • MANUAL MACHINIST
    Temporary - Bodmin, Cornwall
    £10 per hour (Full Time)
    Read more
  • MAINTENANCE WORKER
    Temp to Perm - Penzance, Cornwall
    MB 37121
    Read more
  • BOOKKEEPER
    Permanent - St Austell, Cornwall
    c£20,000 (Full time 09:00-17:15)
    Read more
  • PLUMBER & HEATING ENGINEER
    Permanent - Truro, Cornwall
    £34,000 DOE (Full Time)
    Read more
  • FOOD PRODUCTION ASSISTANTS
    Temporary - Redruth, Cornwall
    £7.83 per hour (0800-1500)
    Read more
  • FOOD PRODUCTION MACHINE OPERATIVE
    Temp to Perm - Redruth, Cornwall
    7.83/Hour to start
    Read more
  • GROUNDSWORKER
    Temp to Perm - Launceston, Cornwall
    £Dependent on Experience
    Read more
  • CARPENTER
    Temp to Perm - Truro, Cornwall
    £10.50/Hour (Full time)
    Read more
  • PACKING SUPPORT
    Temporary - Newquay, Cornwall
    £8.30 per hour (0800-1600)
    Read more
  • ADMIN AND MARKETING SUPPORT
    Temporary - Bodmin, Cornwall
    £8.50 per hour (Full time)
    Read more
  • DUCT FITTER
    Permanent - Truro, Cornwall
    £12.50/Hour
    Read more
  • PASTY CRIMPERS
    Temp to Perm - Redruth, Cornwall
    £7.83/Hour
    Read more
  • CLASS 2 DRIVER
    Temp to Perm - Redruth, Cornwall
    £9.00 per hour
    Read more
  • FINANCIAL CONTROLLER (PART-TIME)
    Permanent - Bodmin, Cornwall
    £27-30K/Annum Pro Rata
    Read more
  • STORES OPERATIVE
    Permanent - Hayle, Cornwall
    £16,600
    Read more
  • SENIOR MECHANICAL DESIGN ENGINEER
    Temporary - Hayle, Cornwall
    £40k-£60k DOE (Full Time)
    Read more
  • FORK LIFT OPERATORS
    Temporary - Cornwall
    From £8.88-9.66/Hour
    Read more
  • SOFTWARE DEVELOPER
    Permanent - Truro, Cornwall
    to £40K/Annum
    Read more
  • WAREHOUSE AND PRODUCTION STAFF
    Temporary - Bodmin, Cornwall
    £8.00 per hour (0800-1630)
    Read more
  • BENCH JOINER
    Permanent - Newquay, Cornwall
    £10/Hour (Full time)
    Read more
  • SOFTWARE DEVELOPER
    Permanent - Bodmin, Cornwall
    £32-40,000 DoE
    Read more
  • PROJECT ENGINEER
    Permanent - Falmouth, Cornwall
    £25-35K/Annum Dependent on Experience (Full Time)
    Read more
  • SOFTWARE DEVELOPER TESTER
    Permanent - Bodmin, Cornwall
    c£35,000/Annum
    Read more
  • MACHINE OPERATIVE
    Temporary - St Austell, Cornwall
    £7.83 per hour (Various shifts available)
    Read more
  • SENIOR SECRETARY
    Permanent - Truro, Cornwall
    £22,000 - £30,000 (DOE) (Full Time)
    Read more
  • PLUMBING AND HEATING ENGINEER
    Permanent - Truro, Cornwall
    £33-34,000/Annum
    Read more
  • RECORDS ASSISTANT
    Temporary - Truro, Cornwall
    £7.83 per hour (9.00am - 17.00pm )
    Read more
  • LEGAL SECRETARY
    Temporary - Truro, Cornwall
    £8.00 + per hour (Full time)
    Read more
  • HOUSEKEEPER
    Permanent - Newquay, Cornwall
    £7.97 - £8.10 per hour (Full time)
    Read more
  • CUSTOMER SERVICE ADMINISTRATOR
    Temp to Perm - Redruth, Cornwall
    £9.20 per hour (Full time)
    Read more
  • FOOD PRODUCTION OPERATIVE
    Temp to Perm - Bodmin, Cornwall
    £7.83 per hour (6.00am - 14.00pm )
    Read more
  • PRODUCTION ASSISTANTS REQUIRED
    Temporary - Redruth, Cornwall
    £8.50 - £9.30 per hour (VARIED)
    Read more
  • DESPATCH OPERATIVES REQUIRED
    Temporary - Launceston, Cornwall
    £8.00 per hour (Nights)
    Read more
  • GRADUATE ENGINEER
    Permanent - Truro, Cornwall
    £Competitive Salary
    Read more
  • MAINTENANCE ASSISTANT
    Temp to Perm - Truro
    £8.20/Hour (Full time)
    Read more
  • IT TECHNICAL SERVICES ENGINEER
    Permanent - Falmouth, Cornwall
    £25-28,000/Annum (Full time)
    Read more
  • KITCHEN PORTERS
    Temporary - Truro, Cornwall
    £7.83 per hour (Various shifts available)
    Read more
  • TRAINEE PRODUCTION OPERATOR
    Temp to Perm - Bodmin, Cornwall
    £7.83 to start
    Read more
  • TELESALES
    Permanent - St Austell, Cornwall
    £18-23,000 + Commission DoE
    Read more
  • IT TECHNICIAN
    Permanent - Falmouth, Cornwall
    to £21,000
    Read more
  • STEEL ERECTOR
    Permanent - St Austell, Cornwall
    £11.50 - 13/Hour DoE (Full time)
    Read more
  • DEV OPS ENGINEER TEAM LEADER
    Permanent - Bodmin, Cornwall
    £Dependent on Experience
    Read more
  • FORK LIFT DRIVER (COUNTER BALANCE)
    Temporary - Newquay, Cornwall
    £8.50/Hour
    Read more
  • MACHINIST
    Permanent - Falmouth, Cornwall
    up to £25k DOE (Full Time)
    Read more
  • WELDER/FABRICATOR
    Permanent - Newquay, Cornwall
    £11 per hour DOE (Full Time)
    Read more
  • JOINER/ASSEMBLER
    Permanent - Redruth, Cornwall
    £8 per hour (Full Time)
    Read more
  • OFFICE MANAGER
    Permanent - Camborne, Cornwall
    £20,000/Annum (Full time, Mon - Fri)
    Read more
  • MIXOLOGIST
    Permanent - Lostwithiel, Cornwall
    £DOE (Various Shifts)
    Read more
  • PLUMBER
    Temporary - Truro, Cornwall
    £10.50/Hour (37.5 Hours/week)
    Read more
  • FIRE AND ALARM SERVICE ENGINEERS
    Permanent - St Austell, Cornwall
    up to £30K DOE (Full Time)
    Read more
  • ELECTRICAL/MECHANICAL ASSEMBLER
    Permanent - Hayle, Cornwall
    upto £26k DOE (Full Time)
    Read more
  • CNC OPERATOR
    Temp to Perm - Falmouth, Cornwall
    £10-£12 per hour DOE (Full Time)
    Read more
  • DEV OPS ENGINEER
    Permanent - Bodmin, Cornwall
    £Dependent on Experience
    Read more
  • TRAINEE CNC OPERATOR AND JOINER
    Temp to Perm - Truro, Cornwall
    £7.83 per hour (Full Time)
    Read more
  • PAINTER & DECORATOR
    Temporary - Redruth, Cornwall
    £11.50 per hour (Full Time)
    Read more
  • JOINER
    Permanent - Falmouth, Cornwall
    £10+ per hour DOE (Full Time)
    Read more
  • STATIC PLANT OPERATOR
    Temp to Perm - St Austell, Cornwall
    £8.10 per hour (Full Time)
    Read more
  • WELDER/FABRICATOR
    Permanent - Hayle, Cornwall
    £26k DOE (Full Time)
    Read more
  • WOOD MACHINIST
    Temp to Perm - Falmouth, Cornwall
    £8.50 per hour (Full Time)
    Read more
  • MAINTENANCE ASSISTANT
    Temporary - Truro, Cornwall
    £8.20 per hour (Full Time)
    Read more
  • TIMBER FRAME ASSEMBLERS
    Temp to Perm - Redruth, Cornwall
    £7.83/Hour to start
    Read more
  • CLASS 2 DRIVER
    Temporary - Redruth, Cornwall
    £10 per hour (Full Time)
    Read more
  • CAR MECHANIC
    Permanent - Truro, Cornwall
    £10-14 per hour DOE (Full Time)
    Read more

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Smith & Reed Recruitment (SW) Limited is a company registered in England & Wales
Company number 661 0875

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