Last updated 20 June 2022

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:

• Prospective and placed candidates for permanent or temporary roles
• Prospective and live client contacts
• Supplier contacts to support our services
• Prospective, current and former employees, consultants, contractors and workers.

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:

• Personal contact details such as name, title, address, telephone numbers, private and corporate email addresses
• Date of birth
• Emergency contact information
• Gender
• National Insurance number
• Evidence of UK residential address
• Current salary information or hourly/daily rate
• Recruitment information – including copies of right to work documentation, references, and other information included in a CV or cover letter or as part of an application process
• Employment history – including job titles, work and education history, working hours, training records and professional memberships
• Disciplinary and grievance information
• Bank account details, payroll records and tax status information
• Pension and benefits information
• Information about your use of our information and communications systems
• Links to your professional profiles available in the public domain, e.g. LinkedIn, Twitter, Facebook or corporate website

We may also collect the following “special categories” of more sensitive personal information:

• Information about your health, including any medical conditions and health and sickness records
• Information about criminal convictions and offences

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:

• The full Uniform Resource Locators (URL)
• Clickstream to, through and from our site (including date and time)
• Products or services you viewed or searched for
• Page response times
• Download errors
• Length of visits to certain pages
• Page interaction information (such as scrolling, clicks, and mouse-overs)
• Methods used to browse away from the page

Information we obtain from other sources.

This is information we obtain about you from other sources such as:

• LinkedIn
• Corporate websites
• Job board websites and online CV libraries
• Facebook
• Twitter
• Your business card
• Personal recommendations
• Background check providers

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:

• Where it is necessary for entering into or performing a contract with you
• Where we need to comply with a legal obligation
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where you have given us consent to use your personal data
• To provide you with the information, products and services that you request from us or we think will be of interest to you if we believe it is relevant to your career or to your organisation
• To provide you with information about other services we offer that are similar to those that you have already purchased, been provided with or enquired about

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:

• Determining, based on your skills, qualifications, and experience, whether you are suitable for a vacancy either within our organisation or with one of our clients
• Determining any terms and conditions on which you engage with us
• Checking you are legally entitled to work in the UK (or other applicable jurisdiction)
• Paying you or your company, and if you are an employee, making deductions for tax and national insurance
• Liaising with your chosen Umbrella organisation, if you are a candidate and supplying services in this manner
• Administering the contract we have entered into with you
• Business management, including compliance auditing and accounting
• Making decisions about your continued engagement or employment
• Making arrangements for the termination of our working relationship
• Dealing with any legal disputes which may arise
• To ensure compliance with legal and regulatory requirements
• Ascertaining fitness to work
• Complying with health and safety obligations
• Monitoring and managing sickness absence
• Liaising with your pension provider
• Conducting performance reviews and managing performance
• Gathering evidence for possible grievance or disciplinary hearings

Consent

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:

• To notify you about changes to our service
• To ensure that content from our site is presented in the most effective manner for you and for your computer.

We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer
• to allow you to participate in interactive features of our service, when you choose to do so
• as part of our efforts to keep our site safe and secure
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them

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

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.

You don’t have to accept them. Most browsers allow you to refuse cookies by activating the relevant setting (please check the help menu of your browser for more details) however, selecting this setting may mean that you are unable to access certain parts of our site.

Please note that unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

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:

• Category 1: Strictly necessary cookies
• Category 2: Performance cookies
• Category 3: Functionality cookies
• Category 4: Targeting cookies or advertising cookies
• Category 1 – Strictly necessary cookies

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.

We do have links to other websites and once you access another site through a link that we have provided it is the responsibility of that site to provide information as to how they use cookies on the respective site.

You can find more information about cookies by visiting www.allaboutcookies.org or www.youronlinechoices.eu. Google also has a brief video which explains the use of cookies.

Disclosure of your information outside of the EEA

We may share your personal information with:

• Any member of our group both in the EEA and outside of the EEA. We will only transfer data outside of the EEA where permitted by law.
• Disclosure of your information within the EEA

We will share your personal information to selected third parties.

Selected third parties may include:

• Clients for the purpose of introducing candidates
• Candidates for the purpose of arranging interviews and engagements
• Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you (or intend to enter into)
• Sub-contractors including email marketing specialists, event organisers, payment and other financial service providers and Umbrella companies
• Analytics and search engine providers that assist us in the improvement and optimisation of our site
• Credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you
• Professional advisors and consultants such as legal and human resource functions

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
• If Intro Consulting Ltd, or a substantial amount of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
• If it is necessary to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use, our terms and conditions for supply of services or to protect or enforce the rights, property, or safety of Intro Consulting Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The lawful basis for the third party processing will include:

• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs
• Satisfaction of their contractual obligations to us as our data processor
• For the purpose of a contract in place or in contemplation
• To fulfil their legal obligations.

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:

• Prior to making an introduction or arranging an interview we check that we have accurate information about you
• We keep in touch with you so you can let us know of changes to your personal data
• We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
• The nature of the personal data and its perceived accuracy
• Our legal obligations
• Whether an interview or placement has been arranged (or requested)
• Whether there has been ongoing communication between you and us
• Whether you are a candidate or an employee
• Our recruitment expertise and knowledge of the industry by country, sector and job role

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.

Your rights

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 connect@withintro.com.

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:

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party in certain formats, if practicable.
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

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 connect@withintro.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.

Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to connect@withintro.com