Privacy Policy
RecruitBlock Privacy Policy
Privacy Policy
Personal data means any information about an individual from which that person can be identified.
Your personal data and privacy is important to us and we are committed to safeguarding your personal data and protecting your privacy.
This privacy policy explains how we achieve that:
RecruitBlock Privacy Policy
This privacy policy applies to:
Candidates applicants for any type of job or engagement via us whose personal data is collected in the course of our services;
Website Users any individual visitors to, and users of, our websites whose personal data is collected by us in the course of the Website Users’ use and navigation around our websites;
Referees referees of Candidates whose personal data is collected in the course of our verification of a Candidate; and/or
Clients and Corporate Staff individuals who work for, or are engaged by, our customers or clients whose personal data is collected in the course of our work with them.
Suppliers individuals who work for, or are engaged by, our suppliers whose personal data is collected in the course of our work with them.
We refer to the above groups of individuals collectively as “you” unless the context dictates otherwise.
Any notices or statements relating to data, data protection, fair processing and/or privacy that we may issue at the time of collecting personal data about you will supplement this privacy policy.
We may change this privacy policy from time to time to reflect changes in the law and/or our personal data handling activities and data protection practices and may not always notify you of the changes.
RecruitBlock Limited
Recruitblock Limited is registered in the UK and Gibraltar
Company No. 09213985 (UK), Kemp House, 152 – 160 City Road, London, EC1V 2N
Company No. 117760 (Gibraltar), Unit 1.02, World Trade Centre, 6 Bayside Road, Gibraltar
We provide specialist professional recruitment consultancy including, but not limited to, Contingency Recruitment, Retained Search, Executive Search, Contract and Interim Recruitment, Start-Ups, Salary Benchmarking, Psychometric Testing, RPO, Employer Branding, Talent Acquisition and Retention, Strategic Employee Planning, Diversity and Inclusion, Relocation, Onboarding, Performance Management and HR Analytics services across the world.
We will typically be the primary data controller of your personal data. The data controller will be referred to as “we”, “us”, “our” from now on within this privacy policy.
There are instances where Recruitblock Ltd act on behalf of a client to process personal data rather as the data controller. For example, where processing interview feedback or timesheets.
The privacy policy or privacy notice of the client will apply in those instances and not this privacy policy.
Where we are a data processor, we will refer you to the applicable data controller and their privacy policy if you have any data protection-related queries.
Our Data Protection Officer
We have nominated a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.
If you have any questions about this privacy notice, including any requests to exercise your legal rights relating to your personal data or if you wish to make a request to access your personal data or to have your personal data removed please contact the DPO using the details set out below:
Email: info@recruitblock.io with a subject title “Data Protection Officer”
Postal: Recruitblock Ltd, Kemp House, 152 – 160 City Road, London, EC1V 2NX, marking it for the attention of the “Data Protection Officer”
Collection and Handling of Personal Data
The applicable data controller will largely be the entity involved in the collection and handling of your personal data. The following other parties may be involved, however:
Third party service providers – we may instruct third parties to assist us to collect and handle your personal data on our behalf.
Third party hyperlinks and connectors – our website and/or services may include links to third party websites. Clicking on those links, or enabling those connections, may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their data protection compliance. When you leave our website, or connect to a third party from us, it is your responsibility to familiarise yourself with their privacy policy or notice, as we accept no responsibility for, and have no control over, them or any information or data collected by or for them.
Personal Data we collect
Personal data means “any information relating to an identified or identifiable individual”.
It does not, therefore, include data where the identity has been removed (anonymous data).
We will collect and handle, process, use, store, share and transfer (generically referred to as handling) the different kinds of personal data about you that is listed under the name of the category of individual that applies to you. Please note, that even though a type of data may be collected, it does not mean that it is collected or retained.
In respect of Candidates and Website Users only, we also handle the following types of data:
- Aggregated Data, such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy; and
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Anonymised Data, which is data created from your personal data where your identity has been removed.
Where do we source your personal data from and how
CANDIDATES: We generally collect your personal data directly from you. For example, we collect your personal data when you:
- Register with us as a candidate;
- Apply for a vacancies as a candidate through our website;
- Submit any other information to us, such as a CV;
- Deal with us in person, by telephone, letter, fax, email, via our website or via our social media channels;
- Complete psychometric assessments or other assessments;
- Subscribe to job alerts emails;
- Subscribe to our publications;
- Enter a competition, promotion or survey; and/or
- Provide us some feedback.
We may also use the following third party channels to collect your personal data:
- Referees – when you are offered a job;
- Former Employees – to confirm dates of employment;
- Educational Institutions – to check your academic qualifications;
- Professional Bodies – to check you professional qualifications;
- Pre-employment screening and background checking organisations;
- Credit Reference Agencies – if we need to check your financial standing;
- Governmental and regulatory bodies such as tax and social security authorities;
- Third party suppliers, including other recruitment and employment agencies, job board providers and job aggregators and our managed service providers who are within our supply chain;
- Your Technical, Profile and Usage Data from our analytics providers, such as Google Analytics, Hubspot and job boards;
- All of your personal data where you were referred to us through a third-party employment agency;
- Clients to whom we have provided your CV and who have engaged with you as part of a job application or who have given feedback on your CV;
Publicly available sources including but not limited to those as set out below:
- Your Identity and Historical Data from social media sites, such as LinkedIn, Twitter and Facebook, to enhance the information we hold about you, in order to help us find more suitable roles for you;
- Your Identity, Contact Data from company and commercial registrars or electoral registers based inside the EU;
PROSPECTIVE CANDIDATES: We will collect personal data about you, including your name and contact details and professional biographical details obtained from publicly available sources such as social media and LinkedIn, so that we can contact you if we think you may be interested in our work finding services. We may also obtain your personal data through another candidate or an employer who recommends you as a contact or prospective candidate.
WEBSITE USERS: We will collect all of your personal data via our third-party service providers, such as Google Analytics and job boards.
As you use our websites, we may automatically collect data about your engagement with our website such as the pages you view. If you contact us, we will also collect information about your enquiry.
We collect this personal data by using cookies, server logs and other similar technologies.
You may also receive Technical Data about you if you visit other websites employing our cookies.
REFEREES: We will collect all of your personal data from a Candidate.
CLIENTS AND CORPORATE STAFF: We will collect your personal data such as your name, job title and contact details, directly from you except where you have previously been a Candidate where we will have also collected personal data in such capacity.
If you provide information to us about a candidate, then we will obtain your details from the candidate and we will keep a record of the personal data that you provide to use about that candidate.
SUPPLIERS: We typically collect your name and contact details as a business contact for your organisation.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter or have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.
CANDIDATES: Your personal data will be collected and handled by us in order to:
- Provide recruitment and/or related intermediary services to or for you;
- Match your details against job vacancies which we feel may be appropriate for you in order to assess your suitability for them;
- Allow you to submit your CV, apply for specific jobs or to subscribe to our job alerts so that we can notify you when relevant job vacancies arise;
- Apply for jobs on your behalf by sending your data to clients;
- Facilitate the recruitment process from there, if the client wishes to progress with you;
- Communicate with you;
- Personalise your experience by creating a candidate profile;
- Send you information and direct marketing for the purposes of informing you about job opportunities, the employment market, industry insights and reports, opportunities to participate in market research and surveys, events, promotions and competitions and to communicate any other relevant information;
- Answer your enquiries or questions;
- Perform statistical analysis to help us understand how out Services are used;
- Diversity monitoring;
- Comply with our regulatory commitments;
- Pursue or defend a legal claim;
- Regulatory monitoring purposes – to prevent or detect crime, where the law requires us to carry out such monitoring;
PROSPECTIVE CANDIDATES: Your personal data will be collected and handled by us in order to:
- Contact you and find out if you are interested in our services;
- Determine if you may be interested in our services and how we can assist you;
WEBSITE USERS: Your personal data will be collected and handled by us in order to:
- To improve and personalise our service and to make the way we operate more useful to you (which includes tailoring our websites to suit your requirements better);
- Let you know about our recruitment services across all areas of our business;
Cookies – When you visit our Site we use cookies to record log data. A cookie is a simple text file that is stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier and the site name.
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Cookie services we use:
Google Analytics collects information about the use of the Services on our website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site, but in anonymous form. Google Analytics collects only the IP address assigned to you on the date you visit this site and assigns a user ID code, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information
REFEREES: we will use your personal data purely to verify a Candidate.
CLIENTS AND CORPORATE STAFF: We will use your personal data to:
- Provide recruitment services to you;
- Communicate with you;
- Get feedback from you on our services;
- Maintain our business relationship with you;
- Answer your enquiries when you contact us;
- Fulfill contractual obligations to you;
- Establish, exercise or defend legal claims;
- Direct marketing purposes;
- Reminders when your products or services may be due for renewal; and
- Opportunities to participate in market research and surveys.
SUPPLIERS: We will use your personal data to:
- Communicate with you;
- Maintain our business relationship with you;
- Answer your enquiries when you contact us;
- Fulfill contractual obligations to you;
- Establish, exercise or defend legal claims;
- Direct marketing purposes;
Opting out/withdrawing consent – you can unsubscribe from receiving marketing communications from us, using the unsubscribe methods contained in email communications we send to you or by contacting us.
Change of purpose – we will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like us to explain how the handling of the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.
Sharing of your personal data
We may share your personal data with the following entities for the purposes set out below:
- Prospective employers or engagers;
- Other recruitment companies or intermediaries involved in managing the supply of personnel;
- Where we are engaged in recruitment process outsourcing and contingent worker management outsourcing activities (RPO), sub-contractors of recruitment services for the RPO;
- Pre-employment screening and background checking organisations;
- Your referees;
- Your past educators and employers and relevant education authorities;
- Your professional bodies;
- Governmental and regulatory bodies such as such as tax and social security authorities;
- The third party suppliers, including other recruitment and employment agencies, job board providers and job aggregators and our managed service providers who are within our supply chain;
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
- The third party suppliers that collect and share Personal Data with us , including other recruitment and employment agencies, job board providers and job aggregators and our managed service providers who are within our supply chain;
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, which includes this privacy policy.
What are the legal grounds for us to collected, handle, use and share your personal data?
We rely on the following legal grounds to process your personal data:
Our legitimate interests or those of a third party including:
- Providing our services to you;
- Responding to your requests and enquiries;
- Informing you about our services;
- Optimising the performance of our website and user experience;
- Ensuring that out operations are conducted in an efficient manner;
Fulfilling a contract – where, in order to fulfill out obligations under a contract with you or to take steps at your request to enter into a contract with us, it is necessary for us to process your personal data;
Compliance with a legal obligation – where we need to process your personal data to comply with legal or regulatory obligations;
Consent – in some circumstances we will ask for your consent to process your personal data in a way, for example if you register or apply for a vacancy on our website. To the extent that we are processing your personal data based upon your consent, you have the right to withdraw your consent at any time. Please contact us if you wish to withdraw your consent.
Storage of your Data
We will not normally transfer your personal data outside of the EEA.
The personal data we collect from you may be transferred outside the EEA either by us and/or by any of the third parties to whom your personal data may be disclosed to as listed. Such transfers will occur only where they are necessary as part of the recruitment and/or related intermediary services we provide, e.g. where you apply for a vacancy or position outside the EEA, or where the transfer is authorised by law.
We, our third party data storage providers and/or the third parties to whom we may disclose your personal data may store your personal data on a server overseas.
If we do transfer your personal data outside the EEA, we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply, or we are authorised to do so.
We will provide you with details of the safeguards that we have implemented if you would like to know what they are.
How your data is looked after
We hold your personal data in a combination of secure IT storage and paper-based files.
We put in place an appropriate level of security around your personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage to it.
We shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of harm that might result from, unauthorised or unlawful processing accidental or unlawful loss, destruction or alteration, unauthorised (or disclosure of) access or damage to your personal data including:
- Locks and security systems;
- Usernames and passwords;
- Virus checking;
- Auditing procedures and data integrity checks; and
- Recording of file movements.
We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and via the access controls listed above. They are also subject to a duty of confidentiality.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority where we are legally required to do so.
If you suspect any misuse or loss of or unauthorised access to your personal data, please let us know immediately by contacting us.
How long will we keep your data for?
We will retain your personal data 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, which may be an ongoing purpose. For example if you are a candidate we will retain your personal data for the duration of our business relationship with you and beyond, as we often support candidates with job placements over many years at various stages of their careers.
We will appropriately and securely dispose of your personal data when it is no longer required.
To determine the appropriate retention period for personal data, we consider the following factors:
- Amount and nature of the personal data;
- Its sensitivity;
- The potential risk of harm from unauthorised use or disclosure of the personal data;
- The purposes for which we handle your personal data;
- Whether we can achieve those purposes through other means; and
- The applicable legal requirements.
Where we process your personal data for direct marketing purposes, we will do so until you ask us to stop and for a short period thereafter to allow us to implement your request. We also retain a record of the fact that you have asked us not to send you direct marketing or to process your data indefinately, so that we can respect your request.
Keeping your personal data up to date
We take reasonable steps to ensure that your personal data is accurate, complete and up to date.
We may contact you from time to time to check that the personal data is still correct.
Please let us know of any changes to your details as soon as you reasonably can so that we can uphold our commitment to accuracy, completeness and currency.
Your legal rights in respect of your personal data that we handle.
We set out below a list of the legal rights that all individuals have under data protection laws in relation to our handling of your personal data.
Right to be informed – about your personal data and details of the handling and processing of that personal data and information, including the safeguards used to protect any of your personal data in the event that we transfer it outside the EEA;
Right of access – to your personal data and to obtain information about how we handle and process it;
Right to have inaccuracies corrected – this is a right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed;
Right of erasure – of your personal data, which is also known as the “right to be forgotten”;
Right to restrict handling and processing – of your personal data, which includes requesting us to suppress your personal data file;
Right to move, copy or transfer– your personal data to another organisation, also known as “data portability”;
Right to object – to the handling and processing of your personal data for certain purposes, in particular to personal data processed for direct marketing purposes and to personal data that is handled and processed for certain reasons based on our legitimate interests;
Right to withdraw consent – you may withdraw any consent or permission that you have previously provided to us in relation to our handling and processing of your personal data, such as for the purposes of marketing by electronic means;
Rights in relation to automated decision making – where such automated decision making has a legal effect on you or otherwise significantly affects you; and
Right to complain – in all circumstances, you may complain to us in relation to the handling of your personal data; or the regulatory body which enforces data protection law in your locality. Click here for a list of contact details.
The aforementioned rights may be limited in certain circumstance, for example if complying with your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you request us to delete information which we are legally required to keep or have compelling legitimate interests for keeping. When we respond to your request we will notify you of any relevant exemptions we are relying on.
Procedure to exercise your legal rights
Contact us – if you wish to exercise any of your legal rights, please email us at info@recruitblock.io with a subject title “Data Protection Officer”. In this instance, we’ll explain first whether or not the right you wish to exercise applies. We will then facilitate your request in accordance with the procedure below if it does apply.
Fees – you will not have to pay a fee to access your personal data or to exercise any other rights that apply. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Our request for further information – we may need to request certain information from you to help us confirm your identity and ensure that your right to access your personal data (or to exercise any of your other rights that apply). This is a security measure to ensure that any personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Response time – we will respond to all legitimate requests as soon as we can. It should not take longer than a month to do so. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.