GraingerWest Limited Client Privacy Notice (“the Notice”)
- 1. GraingerWest Limited is fully committed to protecting and safeguarding your personal information in accordance with applicable data protection legislation. For the purposes of the Notice GraingerWest Limited (“GWL”) will include, where appropriate, GW Risk Limited (“GWR”). Any references to “we” or “us” or similar collective terms in the Notice is to be taken to include reference to one or other of GWL and GWR or both as applicable in the circumstances.
- 2. When we refer in the Notice to client(s), this includes staff employed to work for the client(s) and also staff who are employed to work for any organisations (“RPO(s)”) who provide the client(s) the service of outsourcing a recruitment process. Any reference to “you” or ”your” or similar collective terms in the Notice is to be taken to include reference to client(s) or RPO(s) as detailed
- 3. Compliance with data protection legislation is the responsibility of all employees/staff of GWL who process your personal information
- 4. The Notice explains what personal information we collect, why we collect it, how we use it, the control you have over your personal information and the procedures we have in place to protect it
- 5. In the case that you wish to contact us in relation to your personal information, the Notice includes sections which advises what your rights are and how you can contact us should you wish to do so.
- 6. The Notice applies to personal information processed inside the European Economic Area (the “EEA”). We will not process personal information outside the EEA.
- 7. We will undertake a review of the Notice annually considering any changes to our activities as necessary. We may therefore amend the Notice from time to time to comply with our legal obligations and you should come back and check it whenever you want
ProtectionA. Types of Personal Information
- 1. We collect directly or indirectly some or all of the data in electronic or paper form listed below:
- a) Names
- b) Contact details (telephone numbers (to include personal or work mobile numbers/ email addresses (personal or work)/ office addresses)
- c) Generic financial information (i.e. salary information to include base pay, any bonusses paid and/or any benefits/pension arrangements) about a group of people and not specific to any one employee
- d) Additional information that you to tell us
- 1. We collect personal information in three main ways:
- a) Personal information that you provide to us directly by telephone, during a meeting or by email/messaging
- b) Personal information collected through third parties such as candidates’ that provide your details to act as a referee for them, where appropriate
- c) Personal information from your website or other publicly available online networking site, where appropriate
- 1. We collect personal information about you to provide you with an optimum recruitment service and to fulfil your relevant employment vacancies now or in the future. One way to achieve this is to obtain the clearest picture we can about you and your experience to date.
- 2. We use your personal information in the following ways:
- a) For the purposes of all aspects of the recruitment
- b) For the purposes of legal claims
- 3. Recruitment Use:
- a) Under data protection laws GWL is allowed as part of its legitimate interest for recruitment purposes to use your personal information to effectively facilitate a connection between you and relevant candidates to fill an employment need by both parties
- b) We are of the opinion that it is reasonable for us to proceed on this basis and we will do so unless you let us know that you do not wish to share your personal information with us
- c) We will collect and use your personal information to enable us to offer or provide recruitment services to you, namely relevant candidates that you might consider for roles that you may have (now or in the future).
- d) We will share your personal information with our candidates only where this is necessary to aid and further the recruitment process with you
e) We specifically use your personal information for this legitimate business interest in some or all of the ways set out below, and where appropriate in accordance with our legal obligations to which we are bound, from time to time
- • Storing and updating your personal information on our database so that we can contact you and discuss with you your recruitment needs
- • Storing all written correspondence, notes of telephone conversations, meeting notes, job specifications (to include team structure) and placement of candidates with you so that we can provide specialist recruitment services relevant to you
- • Using your personal information to comply with third party contracts to carry out effectively our legitimate interests
- • Using your personal information for invoicing purposes and/or payroll where appropriate
- • Using your personal information to maintain an organisation chart
- f) For the avoidance of doubt therefore, we will use your personal information to fulfil our legitimate interest and/or with your consent where applicable (for example where we enter into an agreement for services drafted by you or instead an agreement to be bound by our terms of business incorporating the Notice)
- g) You are free, of course, to advise us that you do not wish to be contacted by us and where you do we will desist from such approaches and stop using your personal information. In such circumstances, your personal information (save for your name, email address and our general historic communications with you – this is kept to verify you in the future should we need to and/or to ensure we do not contact you inadvertently in the future) will be deleted.
- h) We have set out at the end of the Notice how to contact us.
- 4. Legal claims:
- a) We are allowed, where necessary, to process personal information in relation to a legal claim. Should this be the case, we will take steps to advise you accordingly and as far as we are able we will process only to the extent that is necessary.
1. Sometimes we will we share your personal information with trusted third parties, for example:
- a) Candidates of ours that have been presented to you for roles, where to do so would assist the recruitment process.
- b) Third-parties who are contracted to perform jobs on our behalf for us to be able to operate effectively as a recruitment business. This would include outsourced IT companies who support our website, other business systems and database storage for example.
2. In all circumstance, we will ensure that:
- a) We provide only the information they need to facilitate the recruitment process with you or to perform their specific services
- b) They may only use your personal information for the exact purpose we specify in our contract with them
- c) We work closely with them to ensure that your privacy is respected and protected at all times d) If we stop using their services, any of your personal information is deleted or made anonymous
- 1. We will take all reasonable and necessary steps to ensure that your personal information is fully protected
- 2. Access to your personal information is electronically password protected and/or contained in a locked filing cabinet in our offices which are fully secured and alarmed. We use trusted IT specialists to regularly monitor our systems and ensure security
- 3. If you think that there has been a loss, misuse or unauthorised use of your personal information please contact us as detailed at the end of the Notice
- 1. We will hold and use in its entirety your personal information on our database for a period of 6 years, provided there has been relevant contact/action (either verbal to written) recorded at any point during the period of 6 years or where there is or has been an agreement with you during this period.
2. Where there has been no relevant contact/action recorded:
- a) For a period of 10 years or longer your personal information will be deleted from our database without review
b) For the period between 6 years to 10 years your personal information on our database will be minimised, which means the majority of your data we hold will be deleted and we will only keep some of it as detailed below:
• Mobile Numbers
• Email addresses
• Recorded general historic communications (verbal and written) The retained information will be kept only for verification purposes and/or to ensure we do not contact you inadvertently in the future should you advise us that you do not want to be contacted by us, as explained in C.3 above
- c) If we are legally required to stop processing your data we will take all necessary steps to comply fully, and if appropriate, remove your personal information from our database
- 1. You have certain rights (as detailed below) in relation to your personal information even if you have previously allowed us to use it.
- 2. You can ask us at any time what information we have about you, to let you have a copy of that information and/or request that we amend or delete some or all of the information.
- 3. We will not charge you for this in most circumstances.
- 4. Only in accordance with our legal obligations, any refusal to provide the information in a request will contain full details of the reason for the refusal.
5. Right to object:
- a) You can ask us to stop processing your personal information based on a number of criteria, but the only one that might apply to us is with regards to our legitimate interest
- b) With regards to such an objection, we will stop processing your personal information unless we can show that we have compelling legitimate reasons to continue the processing.
6. Withdrawal of consent:
- a) Where you have given your consent to use your personal information you have the right to change your mind at any time and withdraw that consent b) Please contact us in writing at the address at the bottom of the Notice c) In such circumstances, we will cease as soon as reasonably practicable unless there is a legitimate and lawful reason to continue
a) You can ask that we erase your personal information in one or more of the following circumstances:
- • Personal information is no longer needed for the purpose that it was originally provided or collected
- • Consent was provided, and you want to withdraw consent
- • Personal information is or has been processed unlawfully
- • We are required to delete the personal information to comply with our legal obligations, this includes being unable to show that we have compelling and legitimate grounds to continued processing based on the legitimate interest condition for processing
- b) We will take all reasonable practicable steps to comply with our duty of erasure of your personal information as soon as reasonably possible
- c) We will, however, retain your name, email address, and general historic communications (verbal or written) for verification purposes only. We will add a notice that you should not be contacted (where appropriate) and that no further information should be collected or used going forward.
- d) If you wish your entire record to be deleted we will comply with this, but you should be aware that this may result in us innocently contacting you in the future. So, if it is the case that you do not wish us to contact you going forward please be aware that where your personal information is erased entirely, we would not be in control of ensuring no future contact
- a) You can ask us to restrict the use of your personal information. In such a case, we will simply hold your data until the reason for the restriction is satisfied or until you instruct us otherwise
- a) You can ask us to rectify any incorrect or incomplete personal information that we have about you.
- b) Where the inaccuracy has been shared we will take steps to advise any third- parties that have the inaccurate/incomplete information and ask them to make the necessary changes, as far as is reasonably practicable
1. If you feel that your data has not been handled in the right way please contact us as detailed below:
- a) Jake Warren 60 Cannon Street, London, EC4 N 6NP
- b) Alternatively, please email firstname.lastname@example.org
2. Further, if this is the case, or if you are unhappy with our response to any requests you have made to us concerning your personal information, you can lodge a complaint at the Information Commissioner’s Office the details are as follows:
- a) Information Commissioner’s Office Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- b) Alternatively, you could email them at email@example.com or www.ico.org/concerns or live chat or call them on 0303 123 1113