Privacy Policy - Brabers

Brabers Consultancy Ltd. is committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data we collect from you or retain about you will be used by us.

Regulation

The General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). GDPR aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally collect, retain and use personal information. GDPR will be enforceable in the UK from 25 May 2018. We are committed to upholding the principles of GDPR prior to its introduction.

For the purposes of GDPR, the data controller is Brabers Consultancy Ltd. of 34 Lower Richmond Road, London, SW15 1JP, United Kingdom

Information we collect and store

We collect information about you to carry out activities relating to our core business as a recruitment business. You might be:

A candidate seeking new work opportunities (permanent or temporary)
A client we engage with to find new candidates
A referee
A supplier or sub-contractor to support our services
An employee (permanent, temporary or on a consultant basis)

The information we collect and retain about you may be different depending on who you are, but will typically include name, address, private and / or corporate e-mail address and phone number, position and company details, compliance documentation and references verifying qualifications and experience and right to work in the United Kingdom, or in the jurisdiction in which you are seeking employment, curriculum vitae, salary and / or rate details and links to professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

Reason for collection and storage of information

As a recruitment business we are dedicated to supporting our candidates’ career aspirations and our clients’ resourcing needs and as such maintain a database of candidate and client personal information containing historical information as well as current resourcing requirements.
A fundamental and essential process of our business is to introduce candidates to clients for permanent employment, temporary work placements or independent professional contracts. Using your information in this way is called our Legitimate Business Interest.

We also use your information to:

Provide you with information and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
Notify you about changes to our service.

In addition to using your information for our Legitimate Business Interest, we may also rely on contract, legal obligation and consent for specific uses of information:

We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information about you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your information and you will be asked for your express consent, if legally required.

Should we want or need to rely on consent to lawfully process your information we will request your consent orally or by email for the specific activity we require consent for and record your response on our systems. Where consent is the lawful basis for processing your information, you have the right to withdraw your consent to this specific processing at any time.

Collection of personal information

We collect personal information from a range of sources, including directly from the information you provide to Brabers Consultancy Ltd. or through third parties we may work with such as sub-contractors in technical and professional services and reference agencies, and through a range of other publicly available sources such as directories, job boards, online CV libraries, social media sites, corporate websites, LinkedIn, Xing and Twitter, business Facebook or corporate website, marketing and event interests.

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.

DISCLOSURE OF PERSONAL INFORMATION

In the course of running our business, we may need to share your personal information with selected third parties either within or outside of the European Economic Area (EEA). Depending on who you are, these third parties may include:

Clients for the purpose of introducing candidates to them.
Candidates for the purpose of arranging interviews and work placements.
Credit reference agencies, our insurance broker, compliance partners or 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.
Suppliers or sub-contractors for the performance and compliance obligations of any contract we enter into with them or you.
Suppliers or subcontractors to support our services.

We may also disclose your personal information to third parties in the following circumstances:

If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Brabers Consultancy Ltd., our candidates, clients, or others.

The lawful basis for third parties to process your personal information include:

Their own legitimate business interests.
Satisfaction of their contractual obligations to us as our data processor.
For the purpose of a contract in place or in contemplation.
To fulfill their legal obligations.

We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so.

Please be aware that we are not responsible for the data processing activities of others, such as our clients.

If you provide us with information about other individuals, like details of a referee or personal contact, you must ensure they’ve agreed to this. We would advise you to keep a record of their agreement and provide them with a copy of, or link to, this Privacy Policy.

Storage and processing of information

The information that we collect from you may be transferred to, and stored at, a destination within Brabers Consultancy Ltd. It may also be transferred to third parties outside of the EEA for the purpose of providing our recruitment services. By submitting your personal information, you agree to this transfer, storing or processing. Brabers Consultancy Ltd. will take all reasonable steps to ensure that your information is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on secure cloud servers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of information transmitted to us. we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

All of the data we capture is stored on a secure cloud server. It is only accessible by authorised users and we deploy many security systems to ensure unauthorised access.

Retention of information

We understand our legal duty to retain accurate information and only retain personal information for as long as we need it for our legitimate business interests. Accordingly, we have a data retention notice and routinely run reports to identify and remove data that we no longer have a legitimate business interest in maintaining.

We try to ensure the information we hold about you is accurate by:

Enabling you to manage your information by contacting our Data Protection Officer at GDPR@brabers.co and to review whether the details we hold about you are accurate.
Enabling you to keep in touch with us so you can let us know of changes to your personal information.

The criteria we use to determine whether we should retain your personal information includes:

The nature of the personal information.
The perceived accuracy of the information.
Our legal obligations.
Whether an interview or placement has been arranged.
Our recruitment expertise and knowledge of the industry by country, sector and job role.
Whether you have told us you want to be contacted about future job opportunities.

Due to legal obligations, we may archive part or all of your personal information or retain it on our financial systems only, deleting all or part of it from our system. We may anonymise parts of your information, particularly following a request for suppression or deletion of your information. If your information is deleted we will have no records remaining, so may re-engage with you if your information is available in a public location.

Our current retention notice is available upon request.

Rights under the GDPR

You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before holding your information) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes, and we will collect express consent from you if legally required prior to using your personal information for marketing purposes.

You can exercise your right to accept or prevent such processing by emailing GDPR@brabers.co and requesting this.

The GDPR provides you with the right 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 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 your personal information. This enables you to ask us to suspend the processing of your personal information, 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. In the first instance we would ask to you to contact us at GDPR@brabers.co and register the issues, allowing us to respond within 14 days. If you are not satisfied with the response, we suggest you contact 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

GDPR gives you the right to access information held about you. We encourage you to contact us to ensure the information we hold about you is accurate and complete.

Your right of access can be exercised in accordance with the Data Protection Act 1998 and the GDPR once it is in force from 25 May 2018.

A subject access request should be submitted to GDPR@brabers.co.

CHANGES TO OUR PRIVACY NOTICE

Any changes we make to our privacy notice in the future will be posted on this webpage www.brabersconsultancy.com and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

CONTACT

Questions, comments and requests regarding this privacy notice should be addressed to our Data Protection Officer at GDPR@brabers.co.