Introduction
Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
• 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, providing our clients with a recruitment solution service, or you are visiting our website.
• CRS Professionals want to provide you with the best possible employment opportunities that are tailored to you. We are a recruitment business providing work-finding services to work seekers/candidates and recruitment solutions to our clients. In order to do this, we must process your personal data (including sensitive personal data) so that we can provide these services to the best of our ability – in doing so, we act as data controller.
• You may give your personal details to us 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. We must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and 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
CRS Professionals (UK) Ltd. will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with our recruitment services and to facilitate the recruitment process. When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy. Our recruitment services and the recruitment process 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.
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.
The legal bases we rely upon to offer these 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
• Where it protects the vital interests of you or another person
b. Legitimate interest
This is where we have a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where we have relied on a legitimate interest to process your personal data our legitimate interests are as follows:
• Providing work finding services to you, including sending your information to our clients where you have demonstrated an interest in doing that particular type of work but have not expressly consented to passing on your cv, and providing you with tailored job recommendations
• Confirming references, qualifications and criminal records to the extent that it is appropriate and in accordance with local laws
• Internal administrative activities like payroll and invoicing where relevant
• Managing our database and keeping our candidates records up to date
• Contacting you to seek your consent where required
• Contacting you with information about similar products or services that you have used from us recently
c. Recipients of data
We will process your personal data and/or sensitive personal data with the following recipients:
• Clients that CRS Professionals (UK) Ltd introduce or supply individuals/our candidates to e.g. design consultancies, architectural practices, property developers, house builders, main contractors, sub contractors, local authorities, housing associations and property consultancies;
• Candidates former or prospective new employers that we obtain or provide references to, educators and examining bodies and employment and recruitment agencies;
• Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, insurers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
• Third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job;
• 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);
• Bibby Financial Services & RSM Employer Services Limited for payroll processing and invoicing
• E-Recruit CRM Provider (staffing software solutions provider)
• Umbrella companies that your data is passed to
• Other recruitment companies that may be in a supply chain e.g. Master/neutral vendors and second tier suppliers
• Social Networks such as LinkedIn, Facebook, Twitter
• Companies House
• Government, law enforcement agencies and other regulators e.g. The Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs) GLAA
• Any organisation you ask us to share your data with
d. Statutory/contractual requirement
The personal data we collect from you is required by law or to enable us to fulfil our contractual duties to you or to others (e.g. our client may require this personal data). Where appropriate, some, for example a candidates’ social security number or religious affiliation, are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements i.e. supply or introduce you to a client or, in extreme cases, may not be able to continue with our relationship.
2. 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.
3. 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.
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 data we will do so in line with our retention policy (a copy of which is attached). 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.
4. Data from our website
a. What information do we collect on our site?
We collect two types of data and information from Users on our website.
The first type of information is unidentified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).
The second type of information Personal Information , which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:
Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
Registration information: When you register with our Site or apply to a job, you will be asked to provide us certain details such as: full name; email or physical address, telephone number and upload other information such as your CV.
b. How do we receive information about you?
We receive your Personal Information from various sources:
When you voluntarily provide us with your personal details in order to register on our Site or apply to a job;
When you use or access our Site in connection with your use of our services;
From third-party providers, services and public registers (for example, traffic analytics vendors).
c. How is the information used? With whom do we share the information?
We do not rent, sell or share Users’ information with third parties, except as described in this Privacy Policy.
We may use the information for the following:
Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
To communicate with you and to keep you informed about our latest updates and services;
To serve you advertisements when you use our Site (see more under "Advertisements");
To market our websites and products (see more under "Marketing");
For statistical and analytical purposes, intended to improve the Site.
In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.
In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes:
Hosting and operating our Site;
Providing you with our services, including providing a personalised display of our Site;
Storing and processing such information on our behalf;
Serving you with advertisements and to assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
Providing you with marketing offers and promotional materials related to our Site and services;
Performing research, technical diagnostics or analytics;
We may also disclose information if we have good reason to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.
d. Cookies
We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.
A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help make sure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.
The Site uses the following types of cookies:
i. 'session cookies'
, which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
ii. 'persistent cookies', which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
c. 'third-party cookies' , which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
We use a tool which is based on the Snowplow Analytics technology to collect information about your use of the Site. The tool collects information such as how often users access the Site, which pages they visit when they do so, etc. The tool does not collect any Personal Information and is only used by our Site hosting and operating service provider to improve the Site and services.
e. Use of script libraries (Google Web Fonts)
In order to present our contents correctly and make them graphically appealing across all browsers, we use script libraries and font libraries such as Google Web Fonts (https://www.google.com/webfonts) on this website. Google Web Fonts are transferred to your browser's cache to avoid multiple loading. If your browser does not support Google Web Fonts or does not allow access, content will be displayed in a default font.
Calling script libraries or font libraries automatically triggers a connection to the library operator. In theory, it is possible – but currently also unclear whether and, if so, for what purposes – that operators of corresponding libraries collect data.
The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy.
f. Third-party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.
This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy.
How do we safeguard your information?
We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorised use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.
g. Advertisements
We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).
You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
h. Marketing
We may use your Personal Information such as your name, email address, telephone number, etc., ourselves or by using our third-party subcontractors, for the purpose of providing you with promotional materials concerning our services which we believe may interest you.
To respect your right to privacy, within such marketing materials we provide you with the means to opt out of receiving further marketing offers from us. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists.
Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.
Corporate transaction
We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Minors
We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow the use of our services by minors without prior consent or authorisation by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at: info@crsprofessionals.co.uk .
Updates or amendments to this Privacy Policy
We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
5. 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 you have the right to withdraw that consent at any time by contacting:
Xara Herriotts, Director of CRS Professionals (UK) Ltd.
Tel: 0121 236 4717
Email address: xara@crsprofessionals.co.uk
Address: Radclyffe House, 66-68 Hagley Road, Edgbaston, Birmingham, B16 8PF
There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting 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.
5. Complaints or queries
If you wish have any general questions about the Site or the information we collect about you and how we use it or wish to complain about this privacy policy or any of the procedures set out in it please contact:
Xara Herriotts, Director of CRS Professionals (UK) Ltd.
Tel: 0121 236 4717
Email: xara@crsprofessionals.co.uk
Address: Radclyffe House, 66-68 Hagley Road, Edgbaston, Birmingham, B16 8PF
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.
Last Modified: 28th November 2018
