Touchstone Recruitment Limited of 167 Oakhill Road, Putney, London, SW15 2QW is the Data Controller
Touchstone Recruitment is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
1. Collection and use of personal data
a. Sources of Personal Data
We have a large variety of sources of Candidate data. We will only ever source data that is necessary to provide services to you and in a way that would be generally expected.
We receive personal data about Candidates from a variety of sources. The primary source is from our Candidates directly. Examples of the sources of personal data of Candidates are as follows:
• the Candidate may send their CV to us with the intention of registering with us to be informed of potential job vacancies;
• the Candidate may apply directly to a position advertised on Touchstone’s website;
• the Candidate may apply to a position advertised on a third party jobs website;
• the Candidate may be sourced from publicly accessible platforms where Touchstone employees are also registered users, for example LinkedIn;
• the Candidate may be sourced from third party CV providers such as jobs websites who provide CV search facilities and where users have made their CV data available to registered customers of these sites;
• we receive Candidate information when the Candidate interacts with our communications e.g. websites and advertisements;
• we may receive personal data about a Candidate from nominated referees of the Candidate or from other Associated Contacts of the Candidate;
• the Candidate may be referred to us from a Client who wishes us to payroll the Candidate as a contractor;
• when we are providing a managed services solution to a client, the Candidate may be referred to us directly from that client requesting that we process their application on their behalf.
b. Categories of personal data we may collect about you
We collect and process personal data only as far as is necessary to facilitate the recruitment process and provide you with work-finding services. We need your personal data in order to find you suitable opportunities and further information may be needed to assess your eligibility through the different stages of the recruitment process.
The information we collect may include your name, email address, telephone number, address, CV’s, identification and right to work documents, educational records, employment history, references, career aspirations, current and future remuneration, pensions and benefit arrangements, notice period, photograph, emergency contact details. If you undertake a temporary assignment under Touchstone Recruitment, we will hold information required for payroll such as bank details, National Insurance number and tax related information. Please note that the above list of categories of personal data we may collect is not exhaustive.
In general, we will not ask you about sensitive personal data but there may be times that it is necessary for information to be disclosed to us and for us to share that with potential employers. We will only share the information where you have provided your explicit consent.
We are also under an obligation with our clients to provide suitable candidates. Part of that assessment will include asking you about any unspent criminal convictions you may have. We consider this to be highly confidential information and will only do so where you have provided your explicit consent.
c. How we use candidate personal data
We will use your information in such ways to facilitate the recruitment process and provide you with work-finding services, including but not limited to:
• Recruitment Services
• Equal Opportunities & Diversity
Our business is to assist and advise Candidates in their search for job opportunities. In providing our services, we may use personal data for the following purposes (we will only ever use the personal data as described here if we have a legal basis for doing so):
• to keep in contact with Candidates, to inform, update and discuss new relevant job opportunities and any subsequent progression through the job search process, for example about interviews, job offers, onboarding, and in the case of contract workers, the timesheet and payment processes;
• to keep up to date information about the Candidate in relation to their job search process and their requirements, in order to assess their suitability for current or future vacancies for example based on their previous skills and experience overall, their own statements about career aspirations, professional development, strengths and weaknesses, their level of managerial experience, professional qualifications;
• to contact referees as part of the recruitment process for permanent roles or as part of the screening process for contract roles;
• to record emergency contact details for contract workers;
• to understand the profile of organisations in which Candidates are currently / previously employed;
• to create a record/file for the Candidate on our internal systems to associate all notes and tracking throughout the job search, interview, placement, onboarding and contracting process;
• to understand current and expected salary, notice period and available, current and required locations in order to enhance and impact the success of the matching process and ensure the Candidate is provided with the most relevant opportunities;
• to develop the relationship between Touchstone Recruitment and the Candidate and ensure a more personalised service;
• to meet the requirements of the Client application process including criminal record and credit checks (where relevant);
• to verify the information provided by Candidates using evaluations and tests (including functional capability and psychometric testing) at the request of the Client;
• to pay referral fees;
• to retain evidential proof of the identity of the Candidate;
• to share Candidate information with Clients. We are not responsible for the processing activities of Clients once a Candidate’s personal data has been shared. Please refer to the Privacy Statement of the relevant Client;
• to carry out our obligations under Client contracts;
• to enable Candidates to participate in our career development services
• to tailor our products and services to better identify the right Candidates and present the right opportunities at the right time and meet Candidate and Client needs more effectively;
We aim to provide Candidates with information that is relevant and personal to the service that they expect to receive from us. When drafting and sending marketing communications, we may use personal data for the following purposes:
• to personalise and make the marketing information sent as relevant as possible;
• to ask for your help in relation to sharing information about opportunities we may have, with your network;
• to aggregate data used as part of surveys or to produce market insights;
• to segment and distribute targeted marketing;
• to follow up with attendees of our events/webinars or to contact attendees about current or future opportunities;
• to ask for your opinion about our products or services;
• to produce aggregated models to predict trends and produce market insights.
We may use and create personal data about Candidates for the purposes of making and receiving payments including the following scenarios (we will only ever use the personal data as described here if we have a legal basis):
• to make an offer of salary and benefits to a Candidate on behalf of a Client in relation to a specific job offer;
• to generate placement activity on our central systems in order to invoice a Client;
• to benchmark salaries for Candidates with similar experience or for companies with similar vacancies;
• to undertake financial audits;
• to communicate payroll and other financial information to Candidates and Clients.
We may need to process certain personal data as part of our legal obligations, and to ensure our recruitment practices are in line with our diversity programmes. We may use personal data for the following purposes (we will only ever use the personal data as described here if we have a legal basis):
• to capture consent/contract acceptance on paper or electronic registration forms, terms & conditions or forms;
• to comply with our legal obligations in respect of: the collection of taxes, levies, contributions; the detection of crime; labour standards; anti-bribery legislation; and industry specific legislation;
• to comply with Client requests relating to their employment practices;
• to comply with the law in certain jurisdictions;
• to fulfil contractual obligations with Clients and vendors, for example, in relation to the enforcement of intellectual property rights.
Equal Opportunities & Diversity
We may process certain personal data as part of our commitment to Equal Opportunities & Diversity, for example to ensure our recruitment practices are in line with our diversity programmes. We may use personal data for the following purposes (we will only ever use the personal data as described here if we have a legal basis):
• to promote diversity or inclusion in the workplace.
A Candidate’s personal data relating to diversity is held anonymously and used for statistical purposes only.
d. Legal Basis
We have to process personal data legally. If we look for consent we will always ensure that Candidates know what they are consenting to. We may also process personal data without consent but only if that is compliant with the GDPR and/or is in line with the reasonable expectations of Candidates and Associated Contacts.
Under the GDPR we must have a lawful basis for processing all personal data. The GDPR sets out the grounds where processing of personal data can be undertaken legally. The main grounds used by Touchstone Recruitment to process personal data are as follows:
The GDPR states that we may process personal data “if necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data”. We may use legitimate interests where we do not have GDPR compliant consent, or where the information is collected indirectly about Candidates. We have assessed the scenarios where we use legitimate interests as a legal ground for processing and we consider our processing is in line with Candidate expectations and that there is a balance between our interests, and those of Candidates. Candidates may object to any processing undertaken on the grounds of legitimate interests. To find out How do you Access / Update / Delete Your Data, please refer to paragraph 4.
Consent may be collected when a Candidate applies to a position advertised on our websites, or when a candidate completes our registration process. Where we are unable to collect consent for a particular processing activity we will only process personal data if we have another lawful ground.
If we have a contract with a Candidate, such as a contract worker, or where the Candidate has entered into a work finding services agreement for the provision of services, we will process personal data in order to fulfil the requirements of the contract, or to undertake set up requirements prior to entering into the contract.
If we have a legal obligation to process personal data, such as the payment of taxes, we will process personal data on this legal ground.
Defence of legal claims
In limited circumstances and in accordance with the law we may use Candidate information in the defence of legal claims or enforcing legal rights, such as IP rights.
e. How we share your data
Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people;
• Individuals and organisations who hold information related to your reference or application to work for us, such as current, past or prospective employers, educators and examining bodies;
• Tax, audit, or other authorities, when we believe in good faith that the law and other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
• Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisors such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
• Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
• Marketing technology platforms and suppliers;
• Potential employers and other organisation to increase your chance of finding employment;
• Third party partners or job boards where we consider this will improve the chances of finding you the right job;
• Third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with laws.
2. Overseas Transfers
The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
3. Data retention
We will delete your personal data from our systems if we have not had any meaningful contact with you for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate we will consider there to be meaningful contact with you if you submit your updated CV onto our website or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you reply directly.
If we place you in a temporary assignment or permanent role we will be required to keep certain information for the specific lengths of time up to a maximum of 6 years. The purpose of keeping this information is to comply with our legal obligations.
4. Your rights
Please be aware that you have the following data protection rights:
• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.
Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Pauline Corcoran, Touchstone Recruitment, 167 Oakhill Road, London, SW15 2QW, telephone 020 3143 4600 or email firstname.lastname@example.org.
There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
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6. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact:
Touchstone Recruitment, 167 Oakhill Road, London, SW15 2QW
[t] 020 3143 4600
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.