ASA Data Privacy Policy

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

    1. Purpose of processing and legal basis
      The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. The legal bases we rely upon to offer these services to you are:
      • Consent
      • Legitimate interest
      • Legal obligation
      • Contractual obligation

    2. Legitimate interest
      Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
      • As agency provides work-finding services to individuals seeking employment

    3. Recipient/s of data
      The Company will process your personal data and/or sensitive personal data with the following recipients:
      • Applicant management system to respond to candidates or move to internal systems
      • CV Formatting system which removes all personal information when sending information out to clients
      • Umbrella Company – Third party payroll business
      • Disclosure Scotland – Where applicable when PVG is require for role
      • Pension Provider – In accordance with Pension Legislation

    4. Statutory/contractual requirement
      Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
      • The agency are unable to provide work-finding services without this information

  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, where applicable to job role, sensitive personal data ie PVG, we will do so in line with our retention practices, outlined below. Upon expiry of that period the Company will cease to process your personal data and sensitive personal data.

    System

    Retention Period

    Advertising / Applicant Management System

    6 months

    CV formatting service

    30 days

    Website - Candidate registration / job alerts

    1 year

    Candidate Management System

    - Candidates who have not registered and not worked for the agency

    - Candidates who have registered but not worked for the agency

    - Candidates worked information will be kept for 7 years

    1 year

    3 years

    7 years

    Payroll System

    7 years

    Skills Testing Software

    Testing Software - 1 week

    Results held on candidate management system as per above time periods


  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 Louise Stanton, who will handle any data protection issues.

  4. Complaints or queries
    If you wish to complain about this privacy notice or any of the procedures set out in it please contact in the first instance:

    Louise Stanton –Data Protection Compliance Manager -

    For any further complaints they should be raised with the Data Protection Lead or Officer depending on severity. Details will be made available when responding to any initial enquiry above.

    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.
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