Introduction

This Privacy Policy aims to explain what we do with your personal data. It describes how we collect, use and process data, and how, in doing so, we comply with our legal obligations to you (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679). Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights, please read the following carefully to find out more.

Who controls your personal data?

At E&A Associates we offer recruitment, headhunting and consulting services. The company responsible for your personal data (‘E&A Associates’ or ‘us’):

• The Data Controller is Eggins and Ascroft Associates Ltd, a company registered in the UK: Company Number 08323890
• Registered office: Unit 2A, Swordfish Business Park, Higgins Lane, Burscough, L40 8JW, United Kingdom
• The Data Controller’s data protection representative is the Managing Director
• You can contact us at info@eggins-ascroft.com

What kind of personal data do we collect?

In order to conduct our business smoothly, we collect personal data from candidates, clients, website users and referees. In this section you can find out more about what kind of personal information we store for each of above mentioned groups:

CANDIDATES

Depending on circumstances, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your interests:

• Name;
• Age/date of birth;
• Sex/gender;
• Photograph;
• Marital status;
• Contact details;
• Education details;
• Qualifications and skills;
• Employment history;
• Emergency contacts and details of any dependants;
• Referee details;
• Immigration status (whether you need a work permit);
• Nationality/citizenship/place of birth;
• Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
• 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;
• Extra information that your referees chooses 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;
• IP address.

CLIENTS

In this case, we collect as little personal data as possible. This relates to individuals working for you (client employer / marketing prospect), and we store the following details:

• Names;
• Telephone numbers;
• Email addresses;
• Position held at the company;
• Extra information that you choose to tell us.

SUPPLIERS

We do not collect much data about Suppliers, i.e. our contacts within supplier’s organisation. We only collect data that we need to make sure that our relationship runs smoothly, and those include:

• Names;
• Telephone numbers;
• Email addresses;
• Bank details;
• Extra information that you choose to tell us.

REFEREES

As part of the recruitment process, sometimes our clients will require references to confirm what we already know about candidates. Therefore, we may ask our candidates to provide us with contact details of their referees, such as:

• Names;
• Telephone numbers;
• Email addresses;
• Position held at the company.

WEBSITE USERS

In terms of our website userswe focus our attention on data and information that may help us with improving your experience whilst browsing and manage services we provide. The data we collect includes:

• Your browser type;
• The location you view our website from;
• The times that our website is most popular.

How do we obtain your personal data?

Again, this depends on what group you represent, please refer to an applicable section below. Please note that those lists are not exhaustive.

CANDIDATES

We may obtain your details in several ways, both from you or from a third party. Most commonly, we will receive data in the following way:

• Directly from you (your CV, application or registration form);
• From a client;
• From another candidate;
• In our researchprocess;
• Marketing databases;
• The public domain;
• Fairs and conferences;
• Interview;
• Telephone or video conferencing with you;
• Notes following a conversation or a meeting;
• Our website;
• Your referees.

CLIENTS

We collect personal data of our clients’ representatives in the following ways

• Directly from you;
• Candidates;
• The public domain;
• Marketing databases;
• Telephone or video conferencing with you;
• Notes following a conversation or a meeting;
• From delegate lists at relevant events;
• Our website;
• Fairsand conferences.

SUPPLIERS

We collect personal data of our suppliers’ representatives in the following ways:

• Directly from you;
• From the third party (recommendation);
• The public domain;
• Marketing databases;

REFEREES

We receive your personal data from our candidates.

WEBSITE USERS

When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services.

How do we use your personal data?

Once we have your personal data we use it in several ways,depending on the circumstances.

CANDIDATES

The processing of personal data may include:

• Collecting and storing your personal data (manual or electronic files);
• Notifying you of potential roles or opportunities;
• Assessing and reviewing your suitability for job roles;
• Introducing and/or supplying you to actual or potential Clients;
• Engaging you for a role with us or with our Clients, including any related administration;
• Collating market or sector specific information and providing the same to our Clients;
• Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment services;
• To market our recruitment services;
• Retaining a record of our dealings;
• Establishing quality, training and compliance with our obligations and best practice;
• For the purposes of backing up information on our computer systems;
• 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.

CLIENTS

We will process your personal data in the context of our dealings with the third party for whom you work and as part of our recruitment services. The processing of personal data may include:

• Collecting and storing your personal data (manual or electronic files);
• Using the data to communicate with you;
• Sending information to third parties with whom we have or intend to enter into arrangements which are related to our recruitment services;
• Actions necessary to further any obligation on us pursuant to a contract between ourselves and the third party you work for;
• Collating market or sector specific information and providing the same to our clients;
• Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers;
• Retaining records of our dealings with you and the organisation whom you represent;
• In more unusual circumstances, to help us to establish, exercise or defend legal claims.

SUPPLIERS

We will use your information:

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

REFEREES

We will use the information that our Candidate gives us about you for the following reasons:

• we will contact you in order to take up a reference;
• If you were put down by our Candidate or a prospective member of Staff as a referee, we may sometimes use your details to contact you in relation to recruitment activities thatwe think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients or Candidates (depending on the circumstances).

WEBSITE USERS

We use personal information to enhance our website and marketing performance.

Who do we share your data with?

As part of our internal operations we may have to share your data, this would include:

• 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/organisationsto increase your chances of finding employment.

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 havingin place a range of appropriate technical and organisational measures, which include:

• Appropriate storage of manual files,
• Password protected storage of electronic files (both offline and online).

Data retention

In most circumstances your data will not beretained for longer than 5 years from the last point at which we provided any services or otherwise engaged with you and it is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. The following sets out the lengths of time we are required by law to retain your data or certain elements of your data:

• Candidates –5 years
• Client / Marketing Prospect –5 years

However, we may retain data for longer than the period stated where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, for example where your personal information identifies specialist skill sets which may remain in demand, or we are subject to a legal obligation which applies for a longer period.

How do we transfer and store your data internationally?

We may need to transfer or store your data internationally, this will happen in following circumstances:

• to third parties (such as advisers or other Suppliers);
• to overseas Clients;
• to a cloud-based storage provider; and
• to other third parties.

We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws.

Our legal basis to for processing personal data

Article 6(1)(f) of the GDPR is the one that we deem relevant here –it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”We don’t think that any of the following activities prejudice individuals in any way –in fact, they help us to offer you a more tailored, efficient service, so everyone’s a winner! However, you do have the right to object to us processing your personal data on this basis. If you would liketo know more about how to do so, please see section below ‘Your rights’.

CANDIDATES

We believe that it is reasonable to expect that if you are looking for employment or have posted your professional CV on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against vacancies we work on. We need to do these things so that we can function as a profit-making business, and to help you and other Candidates get jobs they deserve.

We want to provide you with tailored job recommendations, therefore, we think it is reasonable for us to process your data to make sure that we send youthe most appropriate content.We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection,tax collection or actual or anticipated litigation.

CLIENTS

To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. We think this is reasonable –we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.

SUPPLIERS

We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.

REFEREES

If you have been put down by a Candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services.

Consent

Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:

• you have to give us your consent freely, without us putting you under any type of pressure;
• you have to know what you are consenting to –so we’ll make sure we give you enoughinformation;
• you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
• you need to take positive and affirmative action in giving us your consent –we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We will keep records of the consents that you have given in this way. Also, as we have mentioned, you have the right to withdraw your consent to these activities.

Your rights

One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below and we apply then to all personal data (also for our dealings outside of the EU).

• Request a copy of the personal data that we hold about you. If you would like to make a request for information, please contact us at info@talanoa.me;
• Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data;
• Request that we restrict processingof your data in certain circumstances;
• Request that data is erased where the continued use of that data cannot be justified. Agencies are required to keep certain records such as ID or right to work checks and payroll records for certain periods of time. These obligations will override any request to erase data or any objection to processing for so long as they must keep the data;
• Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process;
• Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations;
• Request inaccurate or incomplete data is rectified. We will respond to such a request within 1 month;
• Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract;
• Make a complaint to the Information Commissioner’s Office https://ico.org.uk
• Request that direct marketing by us to you is stopped.

Complaints

If you are dissatisfied about any aspect of the way, in which your data is processed, you may, in the first instance refer the matter to: info@talanoa.me. This does not affect your right to make a complaint to the Information Commissioner’sOffice: https://ico.org.uk

Phone: 0303 123 1113
Email: casework@ico.org.uk
Post: Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
CheshireSK9 5AF

Contact

If you have any enquires you can contact us at: info@talanoa.me or by writing to us at: Talanoa, Unit 2A, Swordfish Business Park, Higgins Lane, Burscough, L40 8JW, United Kingdom