- Company Name : Sure Recruitment / Sure Training (“the company”)
- Policy No : 15
- Policy Name : Privacy Policy
- Date : Sept 23
- Version : 7
The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company is also a training business which provides driver training to its clients and members of the public.
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 other sources. The Company must have a legal basis for processing your personal data. For the purposes of providing, you with work-finding/ training services and/or information relating to roles or courses relevant to you we will only use your personal data in accordance with the terms of the following statement.
1. Collection and use of personal data
a.Purpose of processing and legal basis
The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding and training services. This includes for example, contacting you about job and training opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job and/or training 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 to comply with laws that apply to us. We record all incoming and outgoing calls on the company landline. We may also use your information during internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to offer these services to you are:
- Your consent
- 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
b. Legitimate interest
This is where 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:
- Managing our database and keeping work-seeker records up to date.
- Providing work-finding services to you and our clients.
- Contacting you to seek your consent where we need it.
- Giving you information about similar products or services that you have used from us recently.
- Giving you information about training that we believe will be of benefit to you.
c Statutory/contractual requirement
The Company has certain legal and contractual requirements to collect personal data (e.g., to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration, and tax legislation, and in some circumstances safeguarding requirements.) Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect, we may not be able to continue to provide work-finding or training services for you.
2. Data retention
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.
Where applicable 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 personal 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 and sensitive personal data.
3. Your rights
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.
Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting your local office.
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.
4 Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it, please contact your local office.
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