PRIVACY POLICY OF WWW.PRSJOBS.COM

BACKGROUND:

Phoenix Resourcing Services (Holdings) Ltd (“PRS”) understands that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value your privacy and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers, Employees and other people whom we may contact in order to find out more about our Candidates or whom they indicate is an emergency contact.

Please read this Privacy Policy carefully and ensure that you understand it.  You will be required to read and accept this Privacy Policy when signing up for an account or submitting information through the Site, but Your acceptance of Our Privacy Policy is deemed to occur upon your first use of the Site.  If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.

1. Definitions and Interpretation 

In this Policy the following terms shall have the following meanings:  

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2. Information About Us

Our Site is operated by Phoenix Resourcing Services (Holdings) Ltd, a limited company registered in England under company number 04401459, whose registered address is 2nd Floor Regis House, 45 King William Street, London EC4R 9AN

The person in charge of data protection at PRS is Richard Snarey and can be contacted by email at feedback-data@prsjobs.com, by telephone on 0207 553 5660 or by post at Coppergate House, 16 Brune Street, London E1 7NJ.

3. What Does This Policy Cover?

This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates, or you are visiting our website.

It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you.  Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites.  Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What Data Do We Collect?

Depending upon your how you interact with us, we may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies):

Candidates

We may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests.  The following list is not exhaustive.

• • Name;

  • Age/date of birth;

  • Sex/gender;

  • Photograph;

  • Marital status;

  • Contact details;

  • Education details;

  • Employment history;

  • Emergency contacts and details of any dependants;

  • Referee details;

  • Immigration status (whether you need a work permit);

  • Nationality/citizenship/place of birth;

  • A copy of your driving licence and/or passport/identity card;

  • Financial information (where we need to carry out financial background checks);

  • Social security number (or equivalent in your country) and any other tax-related information;

  • Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;

  • Details of any criminal convictions if this is required for a role that you are interested in applying for;

  • Details about your current remuneration, pensions and benefits arrangements;

  • Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;

  • Extra information that you choose to tell us or that your referees choose to tell us about you;

  • Extra information that our Clients may tell us about you, or that we find from other third-party sources such as job sites; and

  • CCTV footage if you attend our premises.

Clients

The data we collect about Clients is limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your online engagement with our Site, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements. If we need any additional personal data for any reason, we will let you know. 

Suppliers

The data we collect about Suppliers is limited.  We simply need to make sure that our relationship with you runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements.

Website Users

We collect a limited amount of data from users of our Site, which we use to help us to improve your experience when using the Site and to help us manage the services we provide. This includes information such as how you use our Site, the frequency with which you access our Site, your browser type, the location you view our Site from and the times that our Site is most popular.  If you contact us via the Site, for example by using the chat function, sending us a message or uploading your CV, we will collect any information that you provide to us, for example your name and contact details.

See section 13 for further details.

5. How Do We Collect Your Data?

Candidates

• Personal Data that you give to us.  For example; entering your details on the Site or via an application form, as part of the registration process; giving a hard copy CV to one of Our staff or emailing one to them; applying for jobs through a job aggregator, which then redirects you to our Site; providing your details to us in any other manner, including via social media channels such as Facebook or LinkedIn.

• Personal data that we receive from elsewhere.  For example; your referees may disclose personal information about you; our Clients may share personal information about you with us; we may obtain information about you from searching for potential candidates from third party sources, such as LinkedIn and other websites.

• Personal data we collect automatically.  For example, where you access our Site or read or click on an email from us, where appropriate and in accordance with any local laws, we may also collect your data automatically.

Clients

• Personal data that you give to us.  For example, where you contact us proactively by phone or by email or where we contact you, either directly or as a result of our business development activities more generally.

• Personal data that we receive from elsewhere. Where appropriate and in accordance with any local laws and requirements, we may seek more information from other sources by way of due diligence or other market intelligence including; from third party market research; from delegate lists at relevant events; or from other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them).

• Personal data we collect automatically.  For example, where you access our Site or read or click on an email from us, where appropriate and in accordance with any local laws, we may also collect your data automatically.

Website Users

• Personal data we collect automatically.  For example, where you access our Site there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content.  We also collect your data automatically via cookies, in line with cookie settings in your browser.

6. How Do We Use Your Data?

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. 

Candidates

• Recruitment Activities.

• Collecting your data from you and other sources, such as LinkedIn;

• Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;

• Providing you with our recruitment services and to facilitate the recruitment process;

• Assessing data about you against vacancies which we think may be suitable for you;

• Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;

• Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;

• [Allowing you to participate in specialist online training;]

• Carrying out our obligations arising from any contracts entered into between us;

• Carrying out our obligations arising from any contracts entered into between PRS and third parties in relation to your recruitment;

• Facilitating our payroll and invoicing processes;

• Carrying out customer satisfaction surveys;

• Verifying the details that you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);

• Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and

• Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests.  If you are not happy about this, in certain circumstances you have the right to object (see sections 10, 11 & 12).

• Marketing Activities

• enable us to develop and market other products and services;

• market our full range of recruitment services to you;

• send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you;

• display promotional excerpts from your details on our Site as a success story (only where we have obtained your express consent to do so); and

• provide you with information about certain discounts and offers that you are eligible for by virtue of your relationship with PRS.

We need your consent for some aspects of these activities which are not covered by our legitimate interests and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in. 

Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.

If you are not happy about our approach to marketing activities, you have the right to withdraw your consent at any time. However, we want to let you know that even if you have opted out from our marketing communications, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again. 

• Equal Opportunities Monitoring (and other sensitive personal data)

This diversity information is what is called ‘sensitive’ personal information and slightly stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We'll ask for your consent by offering you an opt-in. This means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.

We may collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your explicit consent. 

If you are not happy about our approach to processing diversity information and other sensitive personal data, you have the right to withdraw your consent at any time.

• To establish, exercise or defend legal claims.

Clients

• Recruitment Activities

• Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities;

• Keeping records of our conversations and meetings, so that we can provide targeted services to you; and

• Undertaking customer satisfaction surveys.

We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests.  If you are not happy about this, in certain circumstances you have the right to object (see sections 10, 11 & 12).

• Marketing Activities

• To establish, exercise or defend legal claims.

Suppliers

We’ve listed below the various ways in which we may use your data in order to establish and maintain our relationship with Suppliers:

• To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;

• To offer services to you or to obtain support and services from you;

• To perform certain legal obligations;

• To help us to target appropriate marketing campaigns; and

• In more unusual circumstances, to help us to establish, exercise or defend legal claims.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.  We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.  If you are not happy about this, in certain circumstances you have the right to object and/or opt out (as appropriate).

Website Users

We use your data to help us to improve your experience of using our Site, for example by analysing your recent job search criteria to help us to present jobs or Candidates to you that we think you'll be interested in.  

Please see section 13 for further information. 

7. How Do We Safeguard Your Data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

Some or all of your data may be stored outside of the European Economic Area (“EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately. 

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8. How Long Do We Keep Your Personal Data For?

We only keep your personal data for as long as We need to in order to use it as described above and/or for as long as We have your permission to keep it.

We will Delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for between two and seven years, as detailed in our Records Retention and Protection Policy (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected. 

For those Candidates whose services are provided via a third-party company or other entity, "meaningful contact" with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.

When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate we will consider there to be meaningful contact with you if you submit your updated CV onto our website or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

9. Do We Share Your Data?

Where appropriate and in accordance with local laws and requirements, we may share your personal data with the following categories of people: 

• Any of our group companies;

• Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;

• Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);

• Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);

• Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;

• Marketing technology platforms and suppliers;

• In the case of Candidates: potential employers and other recruitment agencies/organisations to increase your chances of finding employment;

• In the case of Candidates: third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job;

• In the case of Candidates: third parties who we have retained to provide services such as reference, qualification and criminal convictions checks;

• If PRS merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

10. Your Rights

As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

• • The right to be informed about Our collection and use of personal data;

  • The right of access to the personal data We hold about you (see section 11);

  • The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

  • The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 8 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

  • The right to restrict (i.e. prevent) the processing of your personal data;

  • The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

  • The right to object to Us using your personal data for particular purposes; and

  • Rights with respect to automated decision making and profiling.

If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact are set out in section 14.  Please note that we may keep a record of your communications to help us resolve any issues which you raise.

If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

11. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held) or to exercise any of the other rights referred to in section 10 above.  Please contact Us using the contact details below in section 14 for more details or if you wish to exercise any of your rights under GDPR.

We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

12. How Can You Control Your Data?

In addition to your rights under the GDPR, set out in section 10, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“TPS”), the Corporate Telephone Preference Service (“CTPS”), and the Mailing Preference Service (“MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

You may ask to unsubscribe from job alerts at any time.

You may access some areas of Our Site without providing any data at all.  However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.  However, you may restrict Our use of Cookies. 

13. Our Use of Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. In addition, Our Site uses various analytics services which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. 

14. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at feedback-data@prsjobs.com, by telephone on 0207 553 5660 or by post at Coppergate House, 16 Brune Street, London E1 7NJ.

Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

15.    Updates To Our Privacy Policy

January 2020: Significant changes to the visual layout of the privacy policy and simplification of the wording in Section 13 The Use Of Cookies

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