INTRODUCTION
"AT A GLANCE" SECTION
What kind of personal data do we collect?
CANDIDATE DATA: In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, age, contact details, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks), and national insurance number (and of course you may choose to share other relevant information with us). Where appropriate and in accordance with legislation and requirements, we may also collect information related to your health, diversity information or details of any criminal convictions.
To the extent that you access our website we will also collect certain data from you.
CLIENT DATA: If you are a NL Recruitment customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as: finding Candidates who are the right fit for you or your organisation.
To the extent that you access our website we will also collect certain data from you.
SUPPLIER DATA: We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: In order to provide Candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our Staff, we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidates or Staff members.
WEBSITE USERS: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular.
A number of elements of the personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. 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 or, in extreme cases, may not be able to continue with our relationship.
How do we collect your personal data?
CANDIDATE DATA: There are two main ways in which we collect your personal data:
1. Directly from you; and
2. From third parties.
CLIENT DATA: There are two main ways in which we collect your personal data:
1 Directly from you; and
2 From third parties (e.g. our Candidates) and other limited sources (e.g. online and offline media).
SUPPLIER DATA: We collect your personal data during the course of our work with you.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: We collect your contact details only where a Candidate or a member of our Staff puts you down as their emergency contact or where a Candidate gives them to us in order for you to serve as a referee.
WEBSITE USERS: We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser.
How do we use your personal data?
CANDIDATE DATA: The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with legislation and requirements, we may also use your personal data for things like marketing, and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.
CLIENT DATA: The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. This may involve: identifying Candidates who we think will be the right fit for you or your organisation. The more information we have, the more bespoke we can make our service.
SUPPLIER DATA: The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: We use referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees' personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of a Candidates or Staff member's emergency contacts in the case of an accident or emergency affecting that Candidates or member of Staff .
WEBSITE USERS: We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs to you that we think you'll be interested in. If you are also a Candidate or Client of NL Recruitment, we may use data from your use of our websites to enhance other aspects of our communications with, or service to, you.
Please note that communications to and from NL Recruitment' Staff including emails may be reviewed as part of internal or external investigations or litigation.
Who do we share your personal data with?
CANDIDATE DATA: We may share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want.
CLIENT DATA: We will share your data: primarily to ensure that we provide you with a suitable pool of Candidates;
SUPPLIER DATA: Unless you specify otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: Unless you specify otherwise, we may share your data with associated third parties such as our service providers and organisations to whom we provide services.
WEBSITE USERS: Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.
How do we safeguard your personal data?
We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. Personal data is stored on our database, server and in the case of paper records in a locked storage unit with restricted access.
How long do we keep your personal data for?
If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of two years, we will Delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).
How can you access, amend or take back the personal data that you have given to us?
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time.
Data Subject Access Requests (DSAR): Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or Delete such information. At this point we may comply with your request or, additionally do one of the following:
Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data.
Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.
Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.
Who is responsible for processing your personal data on the NL Recruitment website?
NL Recruitment controls the processing of personal data on its website(s).
What are cookies and how do we use them?
A "cookie" is a bite-sized piece of data that is stored on your computer's hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
How to reject cookies
If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings
Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser's privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website's features. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.
LONG FORM DETAILED SECTIONS
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?
Here's a more detailed look at the information we may collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.
CANDIDATE DATA: Depending on the relevant circumstances and applicable local laws and requirements, 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.
- Name;
- Age/date of birth;
- Contact details;
- Education details;
- Employment history;
- Emergency contacts
- Referee details;
- Immigration status (whether you need a work permit to work in the UK);
- Nationality/citizenship/place of birth;
- A copy of your passport or identity card;
- National insurance number and any other tax-related information;
- Details of any criminal convictions (if this is required);
- Details about your current remuneration, pensions and benefits arrangements;
- Information on your interests and needs regarding future employment.
- 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;
- The dates, times and frequency with which we are in contact with you.
Please note that the above list of categories of personal data we may collect is not exhaustive.
CLIENT DATA: The data we collect about Clients is actually very 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 may also hold extra information that someone in your organisation has chosen to tell us. We also collect contact names and address for sending and processing our invoices to charge you for our services. If we need any additional personal data for any reason, we will let you know.
SUPPLIER DATA: We don't collect much data about Suppliers – we simply need to make sure that our relationship 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.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: All we need from referees is confirmation of what you already know about our Candidate or prospective member of Staff, so that they can secure that job they really want. Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number). We'll also need these details if our Candidate or a member of our Staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.
WEBSITE USERS We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular.
HOW DO WE COLLECT YOUR PERSONAL DATA?
CANDIDATE DATA: We collect Candidate personal data in three primary ways:
1. Personal data that you, the Candidate, give to us;
2. Personal data that we receive from other sources; and
3. Personal data that we collect automatically.
Personal data you give to us
- Entering your details on the NL Recruitment website or via an application form, as part of the registration process;
- Emailing your CV to a NL Recruitment consultant or being interviewed by them;
- Applying for jobs through a job site, which then redirects your application to NL Recruitment.
Personal data we receive from other sources
- 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 Candidate from third party sources, such as LinkedIn and other job sites;
- If you 'like' our page on Facebook or 'follow' us on Twitter we will receive your personal information from those sites.
Personal data we collect automatically
CLIENT DATA We collect Client personal data in three ways:
1. Personal data that we receive directly from you;
2. Personal data that we receive from other sources; and
3. Personal data that we collect automatically.
Personal data that we receive directly from you
- Where you contact us proactively, usually by phone or email; and/or
- Where we contact you, either by phone or email, or through our consultants' business development activities more generally.
Personal data we receive from other sources
- 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 via our website
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. 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.
HOW DO WE USE YOUR PERSONAL DATA?
Having obtained data about you, we then use it in a number of ways.
CANDIDATE DATA: We generally use Candidate data in four ways:
- Recruitment Activities;
- Marketing Activities;
- Equal Opportunities Monitoring; and
- To help us to establish, exercise or defend legal claims.
Here are some more details about each:
- 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 communication about jobs we think may be of interest to you;
- Carrying out our obligations arising from any contracts entered into between us;
- Carrying out our obligations arising from any contracts entered into between NL Recruitment and third parties in relation to your recruitment;
- Facilitating our payroll and invoicing processes;
- Carrying out customer satisfaction surveys;
- Verifying details 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.
Marketing Activities
- enable us to develop and market other products and services;
- market our full range of recruitment services (permanent, temporary and contract) 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.
We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in (which we explain further below).
To help us to establish, exercise or defend legal claims
CLIENT DATA: We use Client information for:
- Recruitment Activities;
- Marketing Activities; and
- To help us to establish, exercise or defend legal claims.
Here are some more details about each:
- 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;
- Undertaking customer satisfaction surveys; and
- Processing your data for the purpose of targeting appropriate marketing campaigns.
To help us to establish, exercise or defend legal claims
SUPPLIER DATA: We will only 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;
- In more unusual circumstances, to help us to establish, exercise or defend legal claims.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: We will only use the information that our Candidate gives us about you for the following purposes:
- If our Candidates or Staff members put you down on our form as an emergency contact, we'll contact you in the case of an accident or emergency affecting them; or
- If you were put down by our Candidate or a prospective member of Staff as a referee, we will contact you in order to take up a reference. This is an important part of our Candidate quality assurance process, and could be the difference between the individual getting a job or not.
- 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 that we 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.
WEBSITE USERS: We use your data to help us to improve your experience of using our website.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
- 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;
- 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: MSP suppliers as part of our clients' MSP programmes;
- In the case of Candidates and our Candidates' and prospective members of Staff's referees: third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws;
- If NL Recruitment 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.
HOW DO WE SAFEGUARD YOUR PERSONAL DATA?
HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?
- we can show that we have compelling legitimate grounds for processing which overrides your interests; or
- we are processing your data for the establishment, exercise or defence of a legal claim.
- the data are no longer necessary for the purpose for which we originally collected and/or processed them;
- where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
- it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
- if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
- to exercise the right of freedom of expression and information;
- to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
- for public health reasons in the public interest;
- for archival, research or statistical purposes; or
- to exercise or defend a legal claim.
- where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
- where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
- where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
- where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
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. Please contact us. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
What's a cookie?
How do we use cookies?
- to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
- Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
- Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics.
- Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
- Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
- Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
- Personalisation cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs that are similar to jobs that you have previously browsed.
OUR LEGAL BASES FOR PROCESSING YOUR DATA
LEGITIMATE INTERESTS
CANDIDATE DATA:
CLIENT DATA:
SUPPLIER DATA:
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS:
- 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 enough information;
- 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.
ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS
Country in which you use NL Recruitment' services or supply NL Recruitment with services: UK
NL Recruitment entity responsible for processing the personal data of Website Users: NL Recruitment Limited
NL Recruitment is responsible for processing the personal data of Candidates, Clients, Suppliers and the emergency contacts and referees of Candidates and NL Recruitment' Staff.
How you can get in touch with us:
ANNEX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY
Country in which you use NL Recruitment' services or supply NL Recruitment with services: UK
Details of your local supervisory authority: The Information Commissioner's Office. You can contact them in the following ways:
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
ANNEX 3 – COUNTRY-SPECIFIC VARIATIONS TO OUR PRIVACY POLICY
PRIVACY POLICY TOPIC: NL RECRUITMENT' PROCESSING OF YOUR SENSITIVE PERSONAL DATA
JURISDICTION: UK
COUNTRY-SPECIFIC LEGAL REQUIREMENT: Where your personal data are processed in accordance with the fair processing condition relating to our rights and obligations under employment and social security law, this relates to our processing of your personal data which is necessary for complia
compliance with legal obligations (such as ensuring that we pay you statutory sick pay, comply with the statutory employment protections that you enjoy, comply with health and safety laws, and ensure that appropriate National Insurance contributions are made).
Cookie Name
AddThis
AdRoll
AdRoll Pixel
AdRoll Roundtrip
AppNexus
DoubleClick
DoubleClick Spotlight
Google Adwords User Lists
Google Analytics
GA Audiences
Google Tag Manager
Google Dynamic Remarketing
Google Adwords Conversion
Facebook Connect
Facebook Custom Audience
iGoDigital (Salesforce Marketing Cloud)
Marketo
Optimizely
Optimizely Geographical Targeting
Optimizely Logging
Sizmek
Taboola
Crazy Egg
Hotjar
GLOSSARY