TRIPLE EDGE SOLUTIONS PRIVACY AND DATA PROTECTION POLICY
INTRODUCTION
This Privacy Policy describes how we collect, control, and process personal data. Our role is as a Data Controller as opposed to a Data Processor.
Data privacy is important to us, and we are committed to protecting and safeguarding all our stakeholder’s data privacy rights.
It is important to point out that we may amend this Privacy Policy from time to time. We will endeavour to keep our policy updated on our website.
This Privacy Policy tells you how we use your personal data, and more importantly, what your rights are in relation to this - you have the right to ask us to delete or confirm the nature of information that we hold about you at any time.
We have three separate, but similar policies. The three policies cover.
• Candidates
• Limited Company Contractors / Temporary Workers
• Clients
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access.
DEFINITIONS
Candidates - include individuals with whom Triple Edge Solutions has not had prior contact, but whom we reasonably consider would be interested in, or might benefit from our services and being considered for any roles advertised or promoted by us including permanent, and temporary positions with our clients.
Candidates also include applicants for such roles, as well as people who have supplied a speculative CV to us not in relation to a specific job, and/or who have engaged with us about our services.
Clients - this category covers our customers, clients, and others to whom we provide services during its business or whom we consider would be interested in our services.
Delete – In this day and age it is virtually impossible to guarantee the permanent and irretrievable deletion of electronic data. In addition, sometimes we will be obliged by law or regulation to retain the ability to access certain elements of data.
General Data Protection Regulation (GDPR) –a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any related national data protection legislation.
Limited Company Contractors / Temporary Workers – includes someone who becomes employed or engaged by Triple Edge Solutions for the purposes of undertaking project work for a client.
If you are a Temporary Worker, we will also continue to process your personal data as a Candidate throughout the duration of your temporary work assignment and thereafter, in accordance with the terms of this Privacy Policy.
DATA PROTECTION POLICY FOR CANDIDATES
The information we 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.
Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below to enable us to assess how we can assist you if we reasonably believe you might be interested in, or might benefit from our services, and to offer you employment opportunities which are tailored to your circumstances and your interests.
In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will only process the data in those jurisdictions to the extent and under the circumstances permitted by law:
• Full Name.
• Nationality / citizenship.
• Contact details.
• A copy of photographic ID (driving licence and/or passport)
• Education and employment information.
• Employment history.
• Skills and languages spoken.
• Referee details.
• Immigration status (whether you need a work permit).
• Start date or availability date.
• Details about your previous and current remuneration, and benefits.
• Financial information (only applicable where we need to conduct financial background checks)
• Criminal conviction data (only applicable for BPSS or security clearance)
Extra information that our clients may tell us about you, or that we find from other third party sources such as job sites (which you have uploaded information onto or is otherwise made available to us).
Additional information that you choose to tell us.
Please note that the above list of categories of personal data we collect is not exhaustive.
How we collect your personal data
We collect Candidate personal data in the following ways:
• Personal data that you give to us.
• Personal data that we receive from other sources.
Personal data you give to us.
We need to know certain information about you to provide you with our services. This will enable us, amongst other things, to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
Personal data we receive from other sources.
We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this will involve personal data received in the following situations:
When we search for Candidates via third party sources, such as LinkedIn and other job sites, from which we obtain your personal information and/or when we conduct other pre-recruitment activities (please refer to the section entitled “Pre-recruitment activities” below).
How we use your personal data
Pre-recruitment Activities
When conducting pre-recruitment activities, we use your data to work out whether you might be interested in, or might benefit from, our services, and to assess whether and how we might be able to assist you. If we think we can help, we will use your contact details to contact you and find out if you are interested in our services, subject to any applicable laws and requirements.
For us to do this, we may:
• Collect your personal data.
• Store your details (and update them when necessary) on our database so that we can contact you about our services.
• Send you an email to inform you about our processing of your personal data and to direct you towards this Privacy Policy.
• Review your information to work out whether and how our services might help you; and
• Contact you about our services.
We have set out in more detail below various ways in which we will use and process your personal data for the purpose of determining whether our services would be beneficial to you, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
Recruitment Activities
Obviously, our main area of work is recruitment – connecting the right Candidates with the right jobs. We have listed below various ways in which we will use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
When we process your information for recruitment activities based on your consent, you have the right to withdraw your consent at any time.
Sharing of data
We will 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.
Retention of your data
We will keep your personal data on our systems for a period of up to two years from the point that we collect such personal data or subsequently have meaningful contact with you (or, where appropriate, the company you are working for or with). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
If you have expressly indicated as a Candidate that you would rather, we didn't retain your personal data, then we will Delete it from our Systems unless we believe in good faith that we need to preserve it, for example, because of our obligations to tax authorities or in connection with any anticipated litigation.
DATA PROTECTION POLICY FOR LIMITED COMPANY CONTRACTORS / TEMPORARY WORKERS
This section of the Privacy Policy applies to Limited Company Contractors and Temporary Workers.
If you are a Temporary Worker, we will continue to process your personal data as a Candidate throughout the duration of your temporary work assignment and thereafter, in accordance with the terms of this Privacy Policy.
The Information we collect.
When we engage with your limited company for a project / programme of works we will, depending on the relevant circumstances and applicable local laws and requirements, collect some or all of the information listed below (in addition to the data collected about Candidates) in order to ensure that our relationship runs smoothly and that we are able to comply with our contractual and other duties to each other, and to our Clients, as part of our relationship and our duties to third parties such as tax authorities and government agencies.
• National Insurance Number
• UTR Reference Number
• Limited Company Registration Number
• Limited Company Address details
• Certificate of Incorporation
• VAT Registration Number and Certificate
• Limited Company Bank Account Details
How we collect your personal data
We collect Candidate personal data in the following ways:
• Personal data that you give to us.
• Personal data that we receive from other sources.
• Personal data you give to us
We need to know certain information about you to provide you with our services. This will enable us, amongst other things, to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
Personal data we receive from other sources.
We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this will involve personal data received in the following situations:
When we search for Candidates via third party sources, such as LinkedIn and other job sites, from which we obtain your personal information and/or when we conduct other pre-recruitment activities (please refer to the section entitled “Pre-recruitment activities” below).
How we use your personal data
Pre-recruitment Activities
When conducting pre-recruitment activities, we use your data to work out whether you might be interested in, or might benefit from, our services, and to assess whether and how we might be able to assist you. If we think we can help, we will use your contact details to contact you and find out if you are interested in our services, subject to any applicable laws and requirements.
For us to do this, we may:
• Collect your personal data.
• Store your details (and update them when necessary) on our database so that we can contact you about our services.
• Send you an email to inform you about our processing of your personal data and to direct you towards this Privacy Policy.
• Review your information to work out whether and how our services might help you; and
• Contact you about our services.
We have set out in more detail below various ways in which we will use and process your personal data for the purpose of determining whether our services would be beneficial to you, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
Recruitment Activities
Obviously, our main area of work is recruitment – connecting the right Limited Company Contractors / Temporary Workers with the right projects. We have listed below various ways in which we will use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
When we process your information for recruitment activities based on your consent, you have the right to withdraw your consent at any time.
Sharing of data
We will share your personal data with various parties, in various ways and for various reasons. Primarily, we will share your information with relevant companies that require your services along with our duties to third parties such as tax authorities and government agencies.
Retention of your data
We will ordinarily process your data throughout the course of your working relationship and will then retain it for a period after we have parted ways. The precise length of time will depend on the type of data, our legitimate business needs and other legal or regulatory rules that may require us to retain it for certain minimum periods. For example, we may be required to retain certain data for the purposes of tax reporting or responding to tax queries.
We may also retain it if it might be relevant to any potential litigation. In jurisdictions that allow it, we will retain personal data relating to you were necessary to enable us to provide you or a future employer with a reference.
DATA PROTECTION POLICY FOR CLIENTS
This section of the Privacy Policy applies to Clients.
Clients include our customers, clients, and others to whom we provide services during its business or whom we consider would be interested in our services.
The information we collect.
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 to enable us to ensure that we can reach out to you about our services, ensure our relationship runs smoothly.
• Contact Names.
• Contact Job Titles
• Contact Telephone Numbers and Email Addresses
• All information relating to the requirements you have (vacancies, specific services) to enable us to satisfy your needs fully. This is likely to include job descriptions, salary, and benefits information.
Sharing your data
We will share information relating to your vacancies with relevant parties only. Primarily we will share your information with prospective candidates to increase your chances of securing the right individual for your needs. At all times, we are happy to engage each individual in a non-disclosure agreement upon your instructions.
Retention of your data
We will retain your data to provide you with services or to receive services from you, or to provide you with information about our services that we believe you may be interested in.
If you have expressly indicated that you are not interested in our services, then we will delete your data from our CRM systems unless we believe in good faith that we need to preserve it, for example, because of our obligations to tax authorities or in connection with any anticipated litigation.
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