For the purposes of data protection legislation in force from time to time the data controller is Intro Consulting Ltd of Studio 4, 224 Shoreditch High Street, London, E1 6PJ.
Intro Consulting Ltd (”We” or “Us”) is committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Your new rights under the GDPR are set out in this notice and apply from 25 May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
What we do
We are a recruitment agency and recruitment business (“our business”). We collect the personal data of the following types of people to allow us to undertake our business:
We collect information about you to carry out our core business activities.
Information we collect about you.
This is information about you that you give us by filling in forms on our website, www.withintro.com (“our site”) or by corresponding with us by phone, e-mail, social media or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, apply to our advertised jobs, attend our events or open days, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
The information we collect about you may include:
We may also collect the following “special categories” of more sensitive personal information:
Information we collect about you when you visit our website.
With regards to each of your visits to our site we will automatically collect the following information: information about your visit, including:
Information we obtain from other sources.
This is information we obtain about you from other sources such as:
In this case we will inform you, by sending you this privacy notice within a maximum of 30 days of collecting the data (unless an exemption applies under GDPR which means that sending the privacy notice will be impossible or disproportionate) of the fact that we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following circumstances:
Our legal basis for the processing of personal data is our legitimate business interests (or those of a third party) described in more detail in the section below, although we may also rely on contract, legal obligation and consent, for specific uses of data.
We will rely on the contract ground if we are discussing/negotiating or have entered into a placement agreement with you or your organisation or any other contract of service or contract for services, contract to provide services to you or receive services from you or your organisation. We will also rely on contract where you apply for a specific job and it is necessary to process your data for the purposes of securing you that role and subsequently entering into a contract with us.
We will rely on the legal obligation ground if we are legally required to hold information on you to fulfil our legal obligations. For example for reasons related to HMRC or employment law.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent if legally required. Examples of when consent may be the lawful basis for processing include obtaining your permission before introducing you to a client (if you are a candidate).
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data are described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates, employees and client contacts. If we discover your CV on a job board, CV database or other location in the public domain, we will rely on legitimate interests when adding your information to our database. We will also consider the use of your personal data in this manner to be within your reasonable expectations.
Once we have added your personal information to our database, we may contact you from time to time via phone or email with details of roles or vacancies which we believe may be of interest to you. If you have applied for a specific role which was unsuccessful, we may also contact you from time to time with alternative roles. You have the right to inform us at any time should you not wish to receive this kind of communication (see the section on Your Rights below).
To deliver our services we may need to use your data for the following purposes:
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
We will use this information:
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process. We will notify you if this changes in the future.
Cookies are files that are recorded in temporary Internet folders on your PC. They’re a useful tool as, by recording the way you use our site, they enable us to get to know you better. For example, we’re able to recognise you when you return to the site, identify your preferences so as to provide you with a more personalised service and speed up searches that you conduct when visiting.
Further Detail on Cookies
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different jobs, like letting you navigate between pages efficiently remembering your preferences and generally improve your website experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
We can split cookies into 4 main categories:
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like register for job alerts, cannot be provided.
Please be aware our site uses this type of cookie.
Category 2 – Performance cookies
These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
By using our website and online services, you agree that we can place these types of cookies on your device.
Category 3 – Functionality cookies
These cookies allow the website to remember choices you make (such as your username and password) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites.
By using our website and online services, you agree that we can place these types of cookies on your device.
Category 4 – targeting cookies or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisations.
Disclosure of your information outside of the EEA
We may share your personal information with:
We will share your personal information to selected third parties.
Selected third parties may include:
We will disclose your personal information to third parties:
The lawful basis for the third party processing will include:
Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our customers or suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
We make sure that security measures are in place to protect your personal data. Measures are also in place to discover any breaches and to enable us to notify the ICO.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests. Accordingly, we have a data retention program and run data routines to remove data that we no longer have a legitimate business interest in maintaining. We are required by law to keep basic information about our candidates, clients and customers for up to 7 years from when our relationship ends, for legal, compliance and tax purposes.
We do the following to try to ensure our data remains accurate and up to date:
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Management (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so. For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms. Pseudonymised data is still personal data however, and we will treat it as such.
You have the right to ask us not to process your personal data for marketing purposes. You can exercise the right at any time by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights. To:
Access to information
You have the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the GDPR.
A subject access request should be submitted to email@example.com. No fee will apply, save for exceptional circumstances.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org