JOSS SEARCH & SELECTION LIMITED
Joss Search and Selection Limited respects your privacy and is committed to protecting your personal data. According to the General Data Protection Regulation of the European Union (GDPR) and the Data Protection Act 2018, there are specific requirements when we process your personal data. This privacy notice will inform you as to which personal data we collect, why we process it, for how long we will process it, with whom we will share your data, as well as your legal rights regarding the processing of your personal data, and how we look after the personal data which you provide to us or which we obtain when you are a Client, Candidate, when you use our website (www.josssearch.com), or when we deal with you in the course of our business.
IMPORTANT INFORMATION ABOUT THE CONTROLLER
Joss Search and Selection Limited (a company with company number 07143280) is the controller and responsible for your personal data (collectively referred to as “Joss Search”, "we", "us" or "our" in this privacy notice).
This privacy notice makes reference to our “Clients”, being businesses that seek our services to source and recruit individuals on their behalf, and our “Candidates”, who are individuals that we source in order to fulfil our Clients’ personnel requirements (on a temporary or permanent basis).
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.
Our full contact details are as follows:
Address: 1st Floor, 81 Piccadilly, Mayfair, London, W1J 8HY
Telephone Number: 02030967050
Data Protection Office: DPO Centre, 50 Liverpool Street, London, EC2M 7PY
Email address: email@example.com
Our website may include links to third-party websites, plug-ins and applications. 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-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE PERSONAL DATA WE COLLECT
Personal data is any information relating to you that allows us to identify you.
For the purposes listed below, we collect, use, store and transfer the following information:
- Identity and Contact Data: personal and identity data, including your name, date of birth, copies of ID, postal address, email address, telephone numbers and information relating to your immigration status and right to work;
- Recruitment Data: references and other information included in a CV or covering letter;
- Financial Data: information regarding remuneration packages offered to Candidates by our Clients including information regarding salary, fee rates, bonuses, expenses and benefits in kind; bank account numbers.
- Technical Data: information we collect automatically when you visit our website or interact with us by email, including your IP address, browser details, and device details;
- Transaction Data: details of services we provide to you;
- Marketing and Communications Data: including your preferences in receiving marketing from us and your communication preferences.
- Photographs and videos: we may take your photograph for promotion and marketing purposes at social events that we hold and you attend, however we will not publish any image of a person without first seeking consent.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services).
We occasionally conduct Disclosure and Barring Service (DBS) checks on our Candidates. Where we carry out DBS checks, we will only do so with a Candidate’s prior written consent. The results of the DBS checks will be shared with our Client with whom the Candidate is being placed.
We have relevant and appropriate safeguards in place which we are required by law to maintain when processing data regarding criminal convictions.
Where we collect your data from
- We collect your data from different sources:
- We collect all of the types of data listed above directly from you when you interact with us;
- We collect Identity and Contact Data from LinkedIn and online job boards;
- We collect data on criminal records from the Disclosure and Barring Service;
- We collect name and contact details from professional contacts or third parties who send us your details as prospective Candidates or Clients;
- We collect Technical Data automatically when you interact with our website or email us or unsubscribe from our mailing list, by using cookies and other similar technologies.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
NOTE: For each processing activity, you can rely on ONE legal basis
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you as a new Client or Candidate||(a) Performance of a contract with you|
|To provide services to you and carry out your instructions in connection with our services||(a) Performance of a contract with you|
|To provide your details as a Candidate to our Clients||(a) Performance of a contract with you|
|To carry out DBS checks on Candidates, and provide details to Clients||(a) Consent
(b) Necessary for our legitimate interests (to ensure the integrity of staff we supply to our Clients)
|To carry out administration in connection with the provision of services to you, including:
(a) Managing payments, fees and charges
(b) Collect and recover money owed to us
|(a) Performance of a contract with you|
|To manage queries relating to services we have provided to you historically||(a) Necessary for our legitimate interests (to be able to respond to queries about our services)|
|To manage our relationship with you as a Client, Candidate or professional contact, which will include:
(b) Asking you to leave a review or take a survey
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how Clients and Candidates use our products/services)
|To enable you to partake in a competition or complete a survey||(a) Consent|
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To send updates to you about vacancies that may be of interest to you||(a) Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To invite you to networking and professional events, including our HR Breakfasts, and to inform you about developments in our business or recruitment/ HR more widely.||(a) Consent (where you have provided positive consent)|
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.
In addition, we may process your personal data without your knowledge or consent where this is required or permitted by law.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our services and vacancies may be relevant for you.
You will receive marketing communications from us in respect of our business and our services/vacancies if you have requested information from us, enlisted with us and, in each case, have given explicit consent to receive that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us using the details above at any time.
Cookies when using our website
DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above:
Third parties who we interact with on your behalf including Clients’ employees and staff and Candidates
Joss Search Inc. Your data may be accessible to our subsidiary organisation in the US.
Service Providers based within the UK, wider EEA or outside the EEA who provide IT and system administration services. For example, Bullhorn recruitment CRM software.
Event Partners who assist us with organising events and marketing those events, including the British Private Equity Venture Capital Association, based in the UK, wider EEA or outside the EEA.
Our professional advisers including lawyers, bankers, auditors and insurers based in the UK or EEA who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs regulators and other authorities based in the UK who require reporting of our processing activities in certain circumstances.
Disclosure and Barring Service for carrying out DBS checks.
Third parties who provide background checks and references.
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 notice.
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.
We may transfer your personal data to third parties providing services to us who are based outside of the European Economic Area (EEA). This includes parties providing IT administration services and hosting services (including Drop Box), and parties providing assistance with managing our marketing databases (including SurveyMonkey).
As stated above, your data may be accessible to our subsidiary organisation in the US.
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- you have expressly consented to the transfer of data;
- transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- using specific contracts with the Service providers approved by the European Commission which give you the same level of protection as when your personal data is processed in the European Unions;
- for providers based in the US, we may transfer data to them if they are part of the Privacy Shield.
- In the case of Joss Search Inc., Standard Contract Clauses are in place to ensure the same level of protection as when your personal data is processed in the European Union
We will only 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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For more details of our specific retention periods, please contact our Data Protection Officer.
YOUR LEGAL RIGHTS
Under certain circumstances you have rights under data protection laws in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out below, please contact our Data Protection Officer.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is repetitive or excessive.
Complaint to the ICO
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your legal rights
Your legal rights are as follows:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you would like to exercise this right, please email firstname.lastname@example.org.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no lawful reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below) or where you have withdrawn your consent to process your personal data that have been processed based on your consent.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain circumstances, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain services to you.