The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company 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. The Company must have a legal basis for processing your personal data.
MTR processes personal data in relation to its own staff, work-seekers and individual client contacts and is a data controller for the purposes of the Data Protection Laws. The Company is registered with the ICO and its registration number is Z1262934
Collection and use of personal data
Purpose of processing and legal basis
The Company has collected your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This 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 Company may hold personal data on individuals for the following purposes:
·Advertising, marketing and public relations
·Accounts and records
·Administration and processing of work-seekers’ personal data for the purposes of providing work-finding services, including processing using software solution providers and back office support
·Administration and processing of clients’ personal data for the purposes of supplying/introducing work-seekers
The legal bases we rely upon to offer these services to you are:
·Your consent (please see our Consent Policy for further information)
·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
We will collect your personal data from you in various ways:
·Directly from you i.e. if you call or email one of our offices
·The MTR website
·From Social Media (ie LinkedIn, Facebook)
·Referred from one of our clients
·An uploaded CV onto a Job Site that we subscribe to
·Referred to us by a Government Department
The Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
·We believe that processing your personal data means that we can continue to provide you with our Recruitment Services.
·Managing our database and keeping work-seeker records up to date;
·Contacting the individual to seek your consent where you need it;
·Providing work-finding services to the individual, including sending your information to our clients where you have demonstrated an interest in doing that particular type of work but not expressly consented to us passing on your cv;
·Contacting the individual with information about similar products or services that you have used from us recently; and
·Passing work-seeker’s information to debt collection agencies.
·You have the right to object to us processing your personal data on this basis.
Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients in order to provide work finding services.
·Clients that we introduce or supply individuals to
·Candidates’ former or prospective new employers that we obtain or provide references to
·The Recruitment and Employment Confederation (and any other trade body that we are a member of who may have access to our candidates’ data)
·Any other third parties who carry out audits to ensure that we run our business correctly
·Payroll service providers who manage our payroll on our behalf
·Any umbrella companies that we pass candidate data to
·Other recruitment agencies in the supply chain (e.g. master/neutral vendors and second tier suppliers)
·Our legal advisers
·Our IT and CRM providers
·Any public information sources and third party organisations that we may use to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS), National College for Teaching and Leadership (NCTL), Nursing and Midwifery Council (NMC), General Medical Council (GMC), DVLA, credit reference agencies, Industry Institutes
·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 of our other offices / group companies;
·Any other organisations an individual asks us to share your data with
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.
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 and sensitive data, we will do so in line with our retention policy. 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.
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.
You have the right to withdraw your consent at any time by contacting firstname.lastname@example.org
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.
Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact email@example.com
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.
*MTR means MTRP Ltd t/a MTR Partnership; The Company