Privacy Policy

Privacy Policy

Context Recruitment Limited is committed to protecting the privacy of our employees, candidates, clients and any other users of our services. This Privacy Notice tells you what to expect in relation to personal information about you which is collected, handled and processed by Context Recruitment Limited.

The Data Controller

Context Recruitment Limited (“Context Recruitment”/”we”, “our”, “us”) is registered as a Data Controller in the United Kingdom with the Information Commissioners Office.

Our registered office is: Ground Floor, Unit 4, Building A East Horton Business Park, Knowle Lane, Fair Oak, Hampshire, England, SO50 7DZ

Telephone Number: 02381 680 400

Email Address: admin@contextrecruit.com

Whose personal information do we process?

In the course of conducting our business activities as a recruitment agency / recruitment business, we process personal data in order to provide effective, recruitment related services. This notice is applicable to any identifiable individual about whom we process personal data. The four main categories of individual for whom we may process personal information are;

Candidate

  • An individual who is seeking employment or other contractual engagement. This includes individuals who are not currently actively seeking employment or other contractual engagement, but may be interested in future employment or other contractual engagement opportunities

Client

  • A business which has engaged us to provide services or which we have identified as a business for which we wish to perform services

Client contact

  • An individual who is employed or engaged by a Client

Referees

  • An individual who has been identified by a candidate, or by us as suitable to provide a written or verbal reference in relation to a candidates prior working history

Supplier Contact

  • An individual employed or engaged by a business, which provides goods or services to us and which may also process personal data relating to any Candidate, Client Contact, Supplier Contact or Referee in the course of performing such services.

What sort of data do we collect?

If you are a Candidate, we may collect, store and process the following types of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
  • Your gender, date of birth, nationality and place of residence;
  • Your professional skills and experience;
  • Your qualifications, training and certifications;
  • Proof of your right to work in the United Kingdom such as copies of your passport and, where applicable, visa, residence permit or similar government documents;
  • Proof of your identity and address, such as copies of your driving licence, utility bills or similar documents;
  • Information about your current or most recent role, including your job title, department, reporting line, responsibilities, salary, benefits and notice period;
  • Your motivation and reasons for seeking new employment;
  • Any information within your CV or any application document which a Client may require you to complete;
  • Any background information which you provide to us during the course of your dealings with us;
  • Details of any Clients to whom you have been introduced by us;
  • Details of any interviews which you have attended and our Clients’ feedback on those interviews;
  • Details of any position which you take up with a Client, including your role, duties, remuneration, department and location;
  • If you provide any services on a freelance basis:
    • Details of any limited company through which you contract and the nature of your relationship with that company;
    • Information about the days and times which you have worked;
    • Your bank details, tax code and National Insurance Number; and
    • Information about any services which you have carried out, including any comments, feedback and issues relating to such services.

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

  • Information about your race or ethnicity;
  • Information about your health, including any medical condition, health and sickness records; and
  • Information about criminal convictions and offences.

If you are a Client Contact, we may collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
  • Your job title and position within the Client organisation; and
  • Any background information relating to your personal circumstances, your work history and the role which you perform within the Client which you may provide to us in the course of your dealings with us.

If you are a Referee, we will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
  • Your job title and position within your employer; and
  • Any background information which you may provide to us in the course of your dealings with us.

If you are a Supplier Representative, we will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
  • Your job title and position within the Supplier organisation; and
  • Any background information relating to the role which you perform within the Supplier which you may provide to us in the course of your dealings with us.

We may collect this information from;

We may collect personal information from a variety of direct or indirect sources;

If you are a Candidate, we may obtain personal data relating to you:

  • Directly if you have:
    • applied for a Client vacancy through us
    • uploaded your CV through our website
    • asked us to provide any work-finding services to you
    • engaged with us through any networking activities or events
    • had any discussions with us about finding alternative employment
  • Indirectly from:
    • online professional networking sites such as LinkedIn
    • social networking sites such as Facebook or Twitter
    • job boards such as Jobsite, Reed, CV Library, Indeed and CW Jobs
    • referees who provide information about your employment experience and their opinion as to your skills and aptitude
    • your employer’s website and other industry-related websites
    • business information directories
    • online industry databases such as the Construction Industry Training Board
    • where appropriate, third-party background checking services such as the Disclosure & Barring Service

If you are a Client Contact or Supplier Representative, we may obtain personal data relating to you:

  • Directly in the course of (i) us providing services to the Client or (ii) the Supplier providing services to us, as applicable; or
  • Indirectly from:
    • online professional networking sites such as LinkedIn
    • your employer’s website and other industry-related websites
    • business information directories
    • other individuals within your organisation in the course of (i) us providing services to the Client or (ii) the Supplier providing services to us, as applicable.

If you are a Referee, we may obtain personal data relating to you:

  • Directly from you in the course of any communications between us; or
  • Indirectly from the Candidate who has nominated you as his or her Referee

How we use personal information

If you are a Candidate, we may use your personal data to:

  • To assess your suitability for employment or other contractual engagement with a client
  • To share your details with our clients and prospective clients for you to be considered for employment or other contractual engagement opportunities
  • To place you in employment or other contractual engagement with our clients
  • To communicate with you in relation potential employment or other contractual engagement opportunities with clients, or in marketing our products and services and to send you details of events, general industry information and other information we think might be of interest to you, where you have consented to being contacted for such purposes.
  • To provide your services to our clients and carry out our obligations relating to any contracts entered into between you and us
  • To fill contractual obligations with our clients
  • To pay you for your services, or arrange for third-party companies through which you may contract to make payments to you
  • To answer your questions and queries
  • To establish that you have the right to work, to undertake security and criminal record checks and to deal with medical and Health and Safety issues relating to certain positions, as permitted by law
  • To satisfy any other legal obligations such as Intermediaries Reporting or exercise our rights in the field of employment and social security and social protection law
  • In order to produce anonymised statistical data

If you are a Client Contact, we may use your personal data to:

  • Communicate with you in order to conduct our services to you as a Recruitment Business, or in marketing our services
  • Contact you for invoicing and credit control purposes;
  • Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime.

If you are a Referee, we may use your personal data to:

  • Contact you to obtain a reference on a Candidate;
  • Provide a copy of the reference to our Client;
  • Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime.

If you are a Supplier Representative, we may use your personal data to:

  • Liaise with you in respect of the services which are being provided by the Supplier;
  • Contact you in relation to billing matters;
  • Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime.

Automated Decision Making

All decisions which are made in the course of our business processes involve human intervention. We do not therefore expect to make any decisions about you using automated means, whether you are a Candidate, Client Contact, Referee, Supplier Representative or other individual.

Legal basis for processing personal data:

Our legal basis for the processing of personal data are as follows:

  1. for the performance of a contract to which you are party to or in order to take steps to enter into a contract;
  2. for the purposes of our legitimate interests or those of a third party.
  3. for compliance with a legal obligation to which we are subject. This includes for the purposes of detecting crime, the collection of taxes or duties, and in order to comply with any applicable law;
  4. Where you give your explicit consent to the processing of your personal data for one or more specific purposes, whereby 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.
  5. for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

Where we have determined Legitimate Interest as the legal basis to process, it is because you are;

  • A Candidate, on the basis that it is necessary for us to maintain a database of individuals who are actively seeking new employment with a Client or potentially suitable for employment with a Client. By processing your personal data and contacting you from time to time, we are able to gain an understanding of your current employment (where applicable), your skills and experience, and your career aspirations. Our processing of your personal data is therefore of benefit to:
  • You, as it assists us to identify new employment opportunities about which you might not otherwise been aware and to give general advice and guidance in support of your career development;
  • Our Clients, who rely on us to have access to suitable, pre-qualified candidates who can fill their requirements; and
  • Us, as we are a business which relies upon being able to introduce Candidates to our Clients
  • A Client Contact, on the basis that we need to be able to contact and interact with the individuals who are employed or engaged by our Clients. This will allow us to effectively provide services to them, better understand their requirements and generate revenue for our business.
  • A Referee, on the basis that we are generally required to obtain references to comply with our contractual obligations to third parties and, in some instances, we are under a legal obligation to do so. It is therefore necessary and reasonable for us to process personal data relating to you strictly for compliance with these obligations.
  • A Supplier Representative, on the basis that we need to be able to contact and interact with the individuals who are employed or engaged by our Suppliers. This will allow us to ensure that our Suppliers provide us with the best possible service which, in turn, is of direct benefit to both our Candidates and our Clients.

Our Lawful Basis for Processing Sensitive Personal Data

[If you are a Candidate, we may also need to process sensitive personal data relating to you. In this event, we will ask for your consent to process this type of data. You are free to decline such consent but it may affect the scope of the services which we can provide to you and the roles for which you may be submitted.]

OR

[If you are a Candidate, we may also need to process sensitive (special) personal data relating to you. The type of sensitive personal data which we might process includes (i) information about any medical conditions or disability insofar as they are relevant to the type of work which you are proposing to carry out (ii) information about any unspent criminal convictions and, where relevant to the type of role which you are carrying out, spent convictions, police warnings etc and (iii) information about any trade union of which you are a member (but only insofar as it relates to an employment claim or pay and working conditions on a client site).

[We are acting as an employment agency and/or an employment business in our dealings with you. In accordance with Article 9 (2)(b) of the GDPR, this sensitive personal data is necessary in the field of employment. i.e. it is required for performing our obligations as an employment agency or employment business and is used solely for this purpose. Any sensitive personal data shall be held strictly in accordance with our policies on data retention and sensitive personal data.

We may also process equal opportunities information relating to you. This shall be anonymised and it is not therefore personal data within the meaning of the Data Protection Legislation.]

Data sharing:

If you are a Candidate, we may share your personal data for legitimate purposes with:

  • A Client where you have expressed an interest in being introduced to such Client or are being supplied to such Client on an assignment;
  • Any third-party which is engaged by the Client to assist them in the recruitment process including a managed service company, Recruitment Process Outsourcing provider or IT platform provider;
  • A third-party company through which you are contracting;
  • A third-party company to which you have specifically asked to be introduced or referred, such as an insurance company or intermediary (umbrella) company;
  • Background checking services such as the Disclosure & Barring Service;
  • Industry bodies such as the Construction Industry Training Board and any similar organisations which are relevant to the market sector in which you work;
  • Third-Party Services Providers who in some cases may use their own subcontractors and sub-processors;
  • Our connected or associated companies;
  • Our bankers and recruitment finance providers;
  • Governmental departments and agencies where we are permitted or required by law to do so.
  • We reserve the right to transfer your information to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of this privacy policy and that the third party only uses your personal data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.
  • We may release personal data to third parties if we believe in good faith that we are required by law to do so in connection in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings;

We may also share your personal data with Clients on an anonymised basis where we have agreed to provide general statistical information to such Clients.

If you are a Client Contact, we may share very limited data relating to you with a Candidate where such sharing is strictly required for the recruitment process e.g. so that the Candidate may contact you directly. We will also share your personal data with Third-Party Services Providers for legitimate business purposes.

If you are a Referee, we will share with our Clients the details of any reference which you may give. We will usually provide your name, job title and employer name when doing so. In some circumstances and only when you have agreed to such disclosure, we will provide your contact details so that our Client may verify the reference or ask for further information. We will also share your personal data with Third-Party Services Providers for legitimate business purposes.

If you are a Supplier Representative, we will share your personal data with other Third-Party Services Providers for legitimate business purposes.

Retention of your data

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Our standard data retention period is three years from the last date on which we are in actual contact with you i.e. where we actually speak with you or exchange correspondence. After this time, we will usually delete your personal data from our records.

Where we are required to keep any information (i) for auditing or compliance purposes (ii) to comply with our contractual obligations to third parties or (iii) in respect of any potential or actual legal proceedings, we shall keep your data for as long as is strictly necessary for these purposes, which is typically for seven years in total. This usually applies in particular to Candidates who we have placed with Clients.

In some circumstances we may completely anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Where your information is held and processed

We have put in place appropriate safeguards to ensure that your data is only transferred to jurisdictions with enforceable data subject rights and effective legal remedies in respect of data privacy breaches. We will therefore only transfer your personal data to jurisdictions outside of the EEA where:

  • There are binding corporate rules in place regarding the transfer of such data within the Group, in accordance with Article 47 of the GDPR. This means that the data transfer is between group companies and those group companies have agreed to share that data in accordance with the rules specified by the European Commission.
  • The European Commission has made an adequacy decision in respect of such jurisdiction. This means that the European Commission has pre-approved the data privacy regime in the relevant non-EEA country. At present, the European Commission-approved jurisdictions are Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the US (limited to the Privacy Shield framework).
  • The transfer of data is subject to the model contractual clauses adopted by the European Commission. This means that we have a data-sharing agreement in place which complies with the requirements set out by the European Commission; or
  • You have expressly given informed consent to the transfer of such data. This means that you have not only agreed to the transfer but have done so in the knowledge that your data may be transferred to a jurisdiction which does not give you the same degree of protection as you have within the EEA.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer.

In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Your rights

You may request access to the information we hold about you at any time. It is important that the information we hold about you is current and accurate. Please inform us if your personal information changes during your working relationship with us.

Upon certain circumstances and subject to legal exemptions, you have the right to;

  • Request a copy of the personal information of which you are the data subject
  • to have any inaccuracies corrected
  • to have your personal data erased
  • to place restrictions on us processing your data
  • to object to processing
  • to request your data to be transferred (data portability)

We may ask you to verify your identity and for more information about your request.

Where we agree to erase your personal data, we will erase all personal data excepting your name and the minimal identifying personal data we perceive as required to identify you on a register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data is collected in unconnected circumstances. You may ask us not to do this.

For more information on your rights please visit the ICO website https://ico.org.uk/

To exercise any or your rights, or for more information contact;

The Data Protection Officer

Ground Floor, Unit 4,
Building A East Horton Business Park,
Knowle Lane,
Fair Oak,
Hampshire,
England,
SO50 7DZ
Telephone Number: 02381 680 400

Email Address: admin@contextrecruit.com

Changes to our Privacy Policy

This Privacy Notice may be changed by us at any time and posted on this website. Where appropriate, we may notify you by email of the changes.