INTRODUCTION

Quality Start Ltd is committed to protecting your privacy in all our dealings with you, whether through our website's on-line services or through direct contact with our consultants.  We work in accordance with the Data Protection Act 1998 and the newly formed EU General Data Protection Regulation (GDPR).  When using our website or dealing with our consultants, we want you to have a safe and secure experience.  We will endeavour to ensure that the information you submit to us remains private and secure, and is only used for the purposes set out in this policy.

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

Candidate Data:

Depending on the requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities.

• Full name
  
• Age/date of birth
  
• Sex/gender
  
• Marital status
  
• Photograph;
  
• Contact details
  
• Immigration status (whether you need a work permit)
  
• Nationality/citizenship/place of birth
  
• Education details
  
• Employment history
  
• Emergency contacts and details of any dependants
  
• Referee details
  
• A copy of your driving license and/or passport/identity card/and or birth certificate
  
• Financial information (where we need to carry out financial background checks)
  
• National Insurance number (or equivalent in your country) and any other tax-related formation
  
• Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information
  
• Details of any criminal convictions if this is required for a role that you are interested in applying for
  
• Details about your current remuneration, pensions and benefits arrangements
  
• Information on your interests and needs regarding future employment
  
• Extra information that you choose to tell us
  
• Extra information that your referees chooses to tell us about you
  
• Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites
  
• IP address
  
• The dates, times and frequency with which you access our services

Please note that the above list of categories of personal data is not exhaustive and we may collect additional information depending on the circumstance.

Client Data:

Depending on the requirements, we collect information about our clients. This information has been detailed but not limited to the list below:

• Company details
  
• Bank details so we can pay you for any refunds, credit notes, etc
  
• Details of individual contacts at your organisation
  • Names
    
  • Telephone numbers
    
  • Email addresses
    
  • Information relating to online engagement
• Information such as testimonials / feedback required for a Preferred Supplier
  
• We may also hold extra information that someone in your organisation has chosen to tell us.

Supplier Data:

Depending on the requirements, we collect information about our suppliers.  This information has been detailed but not limited to the list below:

• Supplier details
  
• Names
  
• Telephone numbers
  
• Email addresses
  
• Bank details so we can pay you
  
• We may also hold extra information that someone in your organisation has chosen to tell us

Data we receive from candidates and our employees such as referees and emergency contacts:

Referees: All we need from referees is confirmation of what you already know about our candidate or prospective member of staff, so that they can secure that job they really want. To ask for a reference, we'll obviously need the referee's contact details (such as name, job title, work address, email address and telephone number).

Emergency contacts: We also collect emergency contact details from our candidate or a member of staff so we can contact them in the event of an accident or an emergency. 

Website Users:

We collect data from our website users. This is to help us improve the users experience with our website. The type of information we collect is listed below:

• Website usage (which pages are visited)
  
• Frequency you access our Website
  
• Browser type
  
• Location you view our website
  
• IP address

HOW DO WE COLLECT YOUR PERSONAL DATA?

Candidate Data:

Primarily we collect candidate personal data in three different ways. Personal data can be provided to us directly by the candidate, received from other sources and collected automatically.

Personal data the candidate gives to us:

In order for Quality Start Ltd to provide you with the best service and opportunities we need to know certain information about you. There are a number of ways you can share this information which are listed below:

• Entering your details on to the Quality Start Ltd website.
  
• Sending an email relating to a job application.
  
• Emailing your CV.
  
• Providing a hard copy of your CV in the post, during a job fair or an interview.

Personal data we receive from other sources:

We also receive personal data about candidates from other sources which include:

• Our clients may share personal information about you.
  
• Your referees may disclose personal information about you.
  
• We may obtain information about you from searching for potential candidates from third party sources, such as
• job sites/boards, LinkedIn and other social media.
  
• A colleague or a friend may recommend you to us.

Personal data we collect automatically:

Through accessing our website or by clicking on an email shot from us, we may also collect your data automatically or through you providing it to us which would clearly state a request for your information.

Client Data:

Primarily we collect client personal data in three different ways. Personal data can be provided to us directly by the client, received from other sources and collected automatically.

Personal data that the client gives to us:

In order to ensure we provide you with the best candidate for your organisation there are two methods in which you would provide us with information:

• Where we contact you, either by phone or email.
  
• Where you contact us by phone or email.
  
• Contact through job fairs or other external events.

Personal data we receive from other sources:

There are a number of ways in which personal data is obtained from other sources. These are listed below:

• Third party market research which we may undertake.
  
• Other third parties such as candidates providing you as a referee.
  
• We may obtain information about your organisation from job sites/boards, LinkedIn and other social media.
  
• A colleague, a friend or another organization may recommend you to us.

Personal data we collect via our website:

Through accessing our website or by clicking on an email shot from us, we may also collect your data automatically or through you providing it to us which would clearly state a request for your information.

HOW DO WE USE YOUR PERSONAL DATA?

Candidate Data:

Once we have obtained your personal data we use it in a number of ways to try and successfully place you into a new role. We primary use your data within the following areas listed below:

Recruitment Purposes:

The primary use of your personal data is to source a role that would be most suitable for you. We have provided a list below which demonstrates how we process your data. If we deem it necessary we may use your data listed below for our legitimate interests.

• Collecting your data directly from you.
  
• Collecting your data from other sources i.e. job sites, social media and LinkedIn.
  
• Saving your data on to our internal database to contact you for future opportunities.
  
• Providing you with our recruitment services to help you fulfil your desired role.
  
• Using the information to undertake talent matching against any potential vacancies.
  
• Sending your information to our Clients for job applications.
  
• Including your data in any contractual documentation.
  
• Information required for our payroll and invoicing processes.
  
• Undertaking customer satisfaction surveys and testimonials.
  
• Verifying details you have provided that may relate to references, qualification etc.
  
• Processing your data to enable us to send you relevant marketing materials or communication which may be of interest to you.

Marketing Activities:    

We may process your data to enable us to send you relevant marketing materials or communication which may be of interest to you. We may use your data for the following purposes and may need your consent for activities which are not covered by our legitimate interest:

• Send you promotional items, details on client events and general news or information relating to recruitment and the industry which may be of interest to you.
  
• Information relating to our recruitment services and industry sectors.

Equal opportunities monitoring and other sensitive personal data:

Some of the data we may collect relates to equal opportunities. This could be information about your ethnic background, gender, age, religion, sexual orientation, or disability. We will use this information on an anonymised basis to monitor our compliance and may share this anonymised data with clients if required.

We may collect sensitive personal information which could be related to religious beliefs, criminal convictions etc. This information would only be collected with explicit consent. Please note that if you decide to withdraw your consent later you are able to do so.

Client Data:

We use Client information to recruit and introduce candidates to you as well as your client information for marketing activities:

Recruitment Activities:

The primary goal for any recruitment agency is to provide you with suitable candidates to fulfil a vacant role.

• Storing your contact details to allow us to contact you for recruitment activities.
  
• Storing your contact details to allow us to contact you for marketing purposes.

Marketing Activities:

We may send you marketing materials via email or post however you do have an option to opt out.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Where appropriate we may share your personal data for various reasons. Please find below a list of those areas where your information could be shared:

• Tax, Audit and any other government authority that may request the data to be shared as part of the law or
• regulatory requirements.
  
• Information related to a reference on a job application to previous, current or future employers and other recruitment agencies.
  
• Third-party service providers, such as accountants, payroll providers, auditors, lawyers and other outside professional advisors; IT systems, support and hosting service providers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
  
• Marketing suppliers.
  
• Data shared with potential employers.
  
• Testimonials / feedback for Preferred Suppliers (PSL)
  
• Managed Service Provider (MSP) programmes for our clients.

HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold. In order to do this we have a number of measures in place which are both technical and process driven. If there are is any suspected breach of data please do get into contact with us.

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will keep your personal data on our systems for a period of 5 years.  We will delete your personal data from our systems if there has not been any contact between us for 5 years.  During the 5 years if there is contact made by the candidate in either writing or verbally that this will be seen as meaningful communication.

WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

Consent:

Quality Start Ltd processes your data with your consent. For example, we rely on your consent when you register with Quality Start Ltd or when you send us your CV for a job application. You have the right to withdraw your consent at any time.  Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn. You may also ask us to confirm what information we hold about you via a Data Subject Access Requests (DSAR).

The processing is necessary to fulfil a contract:

Quality Start Ltd processes your data when we need to do this to fulfil a contract with you, including sending your CV, with your permission, to a client for a specific job application.

Legitimate interest:

Quality Start Ltd also processes your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. Our legitimate interests include:

• As a candidate you are looking for employment or you have posted your professional CV/ information on a job board or professional networking site are happy for us to collect and use your personal data to provide our recruitment services to you. Also, to share that information with prospective employers and assess your skills against our vacancies.
  
• We require your data for our internal administrative activities, like payroll and invoicing where relevant.
  
• Under our Obligations of the Law, it is a legitimate interest of ours, if we believe it is necessary, we may share your data in connection with crime detection, tax collection or actual or anticipated litigation. 
  
• As a Client, we ensure that we provide you with the best service possible. We store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. We will also hold your bank details so we can pay you for any refunds, credit notes, etc. From time to time, we may also ask you to undertake a customer satisfaction survey and testimonials.
  
• As a Supplier, we use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your bank details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
  
• If you have been put down by a Candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.
  
• Protecting candidates, clients, employees and other individuals.
  
• Handling candidate and client contacts, queries, complaints or disputes.
  
• Fulfilling our duties to our candidates, clients, colleagues and other stakeholders.
  
• Ensuring the security and integrity of our Services and in ensuring that our Website operates effectively.

YOUR RIGHTS

Under the UK Data Protection Act 1998, the General Data Protection Regulations 2018 and any subsequent privacy legislation which may apply, you have rights as an individual which you can exercise in relation to the information we hold about you:

• The right to be informed of how your personal data will be stored and used.
  
• The right to access your personal data.
  
• The right to rectification. You have the right to have your personal data modified or updated if it is inaccurate or incomplete.
  
• The right to erase. You may request that all your data is deleted together with that held by third party suppliers. To permanently delete your personal data, send an email to our Data Protection Officer (DPO) Mr Ihthsham Chughtai with the subject line “Permanently delete my information and account”.
  
• The right to restrict processing. You have the right to block or suppress processing of your personal data.
  
• The right to data portability, which allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer your personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
  
• The right to object to processing of your data based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); processing for direct marketing purposes; and processing for purposes of scientific/historical research and statistics.
  
• Rights in relation to automated decision making and profiling, i.e. to not be subject to a decision based solely on automated processing, including profiling.

HOW YOU CAN GET IN TOUCH WITH US:

The Data Controller responsible for your information is Quality Start Ltd.
If you have any questions about this policy or our use of your personal information relating to the points listed below or any other points please do not hesitate to make contact with us:

• To access, amend or take back the personal data that you have given to us.
  
• If you suspect any misuse or loss of or unauthorised access to your personal information.
  
• To withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data).
  
• With any comments or suggestions concerning this Privacy Policy.

If you have any questions about this policy or our use of your Personal Information you can write to our Data Protection Officer, Mr Ihthsham Chughtai, Quality Start, Easterly House, 2nd Floor Offices, 81 Easterly Road, Leeds, LS8 2TW. Alternatively, you can send an email to ihthsham@qualitystart.co.uk.

If you do not think we are handling your Personal Information adequately, you have the right to lodge a complaint with the Information Commissioner’s Office.  Further information, including contact details, are available at https://ico.org.uk