Company Name:              Lighthouse Search & Selection Ltd

Company Contact:          Martin Kearney Data Protection Officer consult@lighthouse-select.co.uk

Telephone Number:      0113 2326443

Document:                        Privacy Notice

Topic                                   Data Protection

Date                                     25th May 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 this privacy statement. At all times we will comply with current data protection laws.

 

Contents

Collection and use of personal data

  1. Purpose of processing and legal basis
  2. Legitimate interest
  3. Statutory/contractual requirement
  4. What data does the company collect / process
  5. Recipients of data

Information to be provided when data is not collected directly from the data subject

  1. Categories of data
  2. Sources of data

Overseas transfers

Data retention

Your rights

Data security

Changes to this privacy statement

Complaints or queries

Collection and use of personal data

Purpose of processing and legal basis

 

 

 

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. 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.

We may wish to contact you to make suggestions and recommendations to you about positions or recruitment news that may be of interest to you and we may wish to include some candidates in our candidate brochure for marketing purposes which we will only do with your consent. We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality insurance.

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

 

2. 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 are as follows:

  • Managing our database and keeping work-seeker records up to date;
  • Providing work-finding services to you and our clients;
  • Contacting you to seek your consent where we need it;
  • Giving you information about similar products or services that you have used from us recently;
  • Providing career / redundancy counselling services authorised by our client;

 

3. 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.

 

4. What data does the company Collect /Process

  • Personal contact details such as name, title, address, telephone numbers and personal email addresses:
  • Recruitment Information (including copies of right to work documentation, references and other information included in a CV or cover letter such as work and education history including training records and professional memberships:
  • Salary, annual leave, notice period, pension and benefits information:
  • Location of employment or workplace:
  • Availability for employment, salary and benefits aspirations, and performance information:
  • People assessment and psychometric information including personality, motivational and aptitude reports:

The company does not collect any sensitive personal data about you (this includes details about your race or ethnicity, religious beliefs or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, criminal convictions and offences and genetic and biometric data).   Health information including where you have a disability will only be processed if you have freely given this information and we have your explicit consent to process this information.

 

5. 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:
  • Companies providing people assessment tools and psychometric measurements as part of a specific recruitment assignment or career development exercise:
  • Clients based outside of the European Economic Area with your explicit prior consent:
  • Other recruitment agencies in the supply chain who are working with the company on a specific assignment (e.g. master / neutral vendors and second tier suppliers:
  • Any other third parties who carry out audits to ensure that we run our business correctly:

We require all third parties to respect the security of your personal data and treat it in accordance with the law.  We do not allow clients to use your personal data for their own purposes, and only permit them to process your personal data in accordance with our terms of business.

 

Information to be provided when data collected not from the data subject

 

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

Personal data:

  • Personal contact details such as title, name, address, telephone numbers, email:
  • CV or Social Media Profile including work and education history, training records and professional membership, Location of employment or workplace:
  • Salary, annual leave, notice period, pension and benefits information:

2. Source of the personal data: The Company sourced your personal data/sensitive personal data:

  • From Jobs Boards, generic and specialist sites:
  • Social Media sites such as LinkedIn:

 

This information came from a publicly accessible source.

 

Overseas Transfers

The Company may 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. We will take steps to ensure adequate protections are in place to ensure the security of your information. 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 data, we will do so in line with our retention policy. Any data we collect will be processed and stored securely, for no longer than is necessary in the light of reasons for which it was first collected, e.g. for consideration against a particular role we are recruiting or other types of assignment we are handling on behalf of our clients.  We will comply with our obligations and safeguard your rights under the GDPR at all times.

Any Data we collect will be deleted no later than 12 months after the opportunity you contacted the company about or the company contacted you about, has been completed, unless you agree to your details being retained on our files.

 

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 Martin Kearney by email consult@lighthouse-select.co.uk   by telephone 0113 2326443. 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.

 

Data Security

The Company takes every precaution to protect our users’ information. Your data will be stored by Lighthouse Search & Selection Ltd in the UK.  Data security is very important to the company and to protect your data suitable measures have been taken to safeguard and secure any data the company holds about you. Steps the company has taken to secure and protect your data include: IT security systems with limited access, use of passwords and systems protected by firewalls and virus protection; password / pin protected mobile devices, storage of all paper documentation in locked rooms / and storage.

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 consult@lighthouse-select.co.uk

 

 Changes to this privacy statement

We will updae 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 Martin Kearney by email consult@lighthouse-select.co.uk   by telephone 0113 2326443.

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.

 

 

Annex A

The lawfulness of processing conditions for personal data are:

  1. Consentof 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 interestsof the individual or another person.
  5. Processing is necessary for the performance of a task carried out in the public interestor 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.

 

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.
  10. 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.