Privacy Policy

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Who Are We? and How Do You Access/Delete Your Data

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We understand and respect your need for privacy and the protection of your personal data.

Walter Everett operates as a recruitment agency and consultancy, serving as a permanent recruitment supplier. Our establishment dates back to 2006, and we specialize in the niche technology recruitment sector. Our registered company number is 5882877, and our Registered Office Address is 15 Queen Square, LS2 8 AJ

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If you have inquiries related to this policy, or if you wish to access or request the removal of your data from our systems, please reach out to us via email with the subject line "Attention of: Data Protection Officer" at contact@waltereverett.co.uk.

As the primary data controllers for your services, it's important to note that certain information concerning salaries and fees, as well as client invoices, is discreetly and electronically shared with our accountancy service providers. Additionally, we employ a reputable third-party Application Tracking System, www.ismartrecruit.com, to securely store your data.

 

What Is Personal Data?

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Personal Data in the UK is defined as:

"‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person."

 

What Are Our Legal Obligations as a Recruitment Agency?

 

By law, we must ensure that our activities, records, data retention, and policies comply with:

• Employment Agencies Act 1973

• The Conduct of Employment Agencies and Employment Businesses Regulations 2003

• Data Protection Act 1998 (superseded by the DPA 2018) and registration with the ICO

• GDPR

• Equality Act 2010

• CAP Code, regulated by the ASA: https://www.asa.org.uk/topic/Recruitment_and_work.html

We are also required by HMRC to retain our accountancy records for 6 years.

Throughout this document, we will highlight when there is a legal reason for processing your data.

Who Regulates the Recruitment Industry?

The UK government has established fair and strict rules to protect job seekers. Employment Agencies are regulated by the Employment Agency Standards Inspectorate (EAS). For more information on your rights or to contact them, you can visit www.gov.uk/government/organisations/employment-agency-standards-inspectorate.

The ICO ensures compliance with data protection policies. Our reference number is Z3068163, and you can find more information on their website at https://ico.org.uk/.

 

What Data Are We Required to Process By Law?

 

We are committed to transparency in how we collect and use personal data to meet our data protection obligations and uphold the law. This policy aligns with the General Data Protection Regulations 2018 (GDPR) and individual rights and obligations concerning personal data.

Walter Everett operates as an employment agency and consultancy. As such, we process data in the form of CVs, verification documents, and compliance documentation, as required by law and our clients. We are mandated by law to comply with General Data Protection Regulations and subsequent Data Protection Laws. Notably, we process special category data when placing candidates.

Who Does This Policy Apply To? and Does Anyone Else Have Access to My Data?

This policy applies to:

• Work Seekers who apply for jobs advertised by us and candidates who supply personal data as part of our service.

• Website Users visiting our website or applying through our third-party Application Tracker System, www.ismartrecruit.com.

• Clients with whom we have agreed terms and conditions to supply our services, as well as the contacts involved in these agreements.

• Our third-party providers and suppliers, including our Accountancy service Provider and ATS Service provider, iSmart Recruit. All our suppliers adhere to this policy. You can read about our main providers' policies on GDPR and data at https://www.ismartrecruit.com/blog-gdpr-compliance-ats-recruiting-software.

• CV Outsourcing companies and third-party advertising intermediaries, which we use to expand our candidate pool. When using these services, we engage in terms and conditions that ensure data is delivered via our ATS system, iSmart Recruit, for transparency.

• Third-Party Hyperlinks: Our website contains hyperlinks and connectors for advertising and informational purposes. If you open these links, those companies may collect data about you. We are not responsible for the compliance of those websites, so we encourage you to carefully read their privacy policies.

 

What Data Does Walter Everett Process and Keep?

 

Walter Everett actively searches for candidates using LinkedIn and various job boards and advertisements. If you apply for a job through us, we provide you with a detailed job description through our ATS, ensuring we have your explicit consent to process your data, including any Special Category Data.

Based on government requirements, we keep data for candidates we aim to find work for. You can find more information here: www.gov.uk/record-keeping-for-employment-agencies-and-businesses/records-about-workseekers. The data we collect serves various legal, contractual, and service obligations:

• Identity: We check that you are who you claim to be, requiring data such as your title, name, and contact information.

• Historical: This includes details disclosed on your CV, such as educational history, work history, relevant skills, training, qualifications, and sometimes references.

• Suitability for a Given Position: Information such as employment data, current remuneration (if necessary), your aspirations, interview feedback, and technical skills and training.

• Verification Data: Legal and client requirements mandate verification data and documents, such as passports and other identity documents. This is considered special category data, and we require explicit consent to process it.

• New Employment Data: Details of successful offers, salaries, benefits, and start dates, along with email correspondence between Walter Everett and you.

• Employment Checks and Information: Our clients conduct background checks, and some client contracts may require us to share information about your previous employment history.

• Technical Data: We collect data regarding your interactions with our systems and website.

• Website and Marketing Data: We collect data related to your website interactions and use this for SEO and marketing improvements.

• Client Data: Details of positions, durations, experience, training, and qualifications required by hirers, including inquiries about the hirer and the position they want to fill.

 

Why, Where, and How We Source Your Data, What We Do With It, and Who We Share It With

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Why: We source and collect data to provide our services to you and our clients. We do this under legal bases and client agreements to perform our duties in assisting you in finding a new job or helping clients place their requirements.

Where and How We Source Your Data:

• Applications: We receive online job applications through advertisements on job boards, external URLs that direct you to our ATS, or email systems. We take measures to encrypt and secure this data.

• Online Social Media Websites: We may contact you through platforms like LinkedIn, Facebook, or Instagram if they allow us to do so.

• Job Boards: We regularly use job boards to source work seekers' data. These job boards have their own data and privacy policies.

• Word of Mouth and Networking: We often ask placed candidates for recommendations, and we also receive recommendations from colleagues and candidates.

• Our Website: You can apply for jobs through our website, which connects to our ATS. If you interact through the website chat, we save your contact details.

• Third-Party CV and Outsourcing Services: We use third-party advertisers to extend our recruitment reach and engage CV sourcing companies to help clients find technical staff.

• Referees, Background Checks, and Security: We may be made aware of sensitive information disclosed by you or clients. Clients may also conduct background checks and reference checks.

 

What We Do With Your Data: We use your data with your explicit consent and as required by law. This includes performing recruitment services, legal and contractual obligations, sending applications on your behalf, matching your details with job vacancies, guiding you through the recruitment process, conducting verification checks, and more.

Who We Share Your Data With: Walter Everett's directors, our third-party ATS supplier (www.ismartrecruit.com), and our accountancy partner have access to your data. We also share data with prospective employers, interviewers, and the providers of our website and marketing services.

 

Your Consent - Legal Obligation

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We request your explicit consent to collect your data in various ways. We ensure that you understand our policies during the application process, discussing roles verbally and via email. You grant consent to send your details to our clients after mutual agreement to make an application on your behalf. If, for any reason, you haven't consented to have your data on our ATS, we may not be able to represent you. We regularly check placement data to ensure that consent is given. If you're unable to provide information that we're legally obliged to gather, we may not be able to work with you.

 

Cookies and Cookie Policy

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We use HTTP cookies to enhance your experience on our website. These cookies are small blocks of data created by a web server and are placed on your computer or device by your web browser. We collect information about your general internet use using these cookies to improve our website. You can adjust your computer settings to decline cookies if desired. For more information, visit AboutCookies.org.

Where Do We Store Your Data and What Do We Do in Case of a Breach?

We store our data with a global service provider in Frankfurt, Germany, without cross-border transfers. Our data is stored in the cloud and electronic format for added security. We have robust security measures, including private VPNs, encryption, and surveillance. Our devices are protected with multiple passwords and are located in secure, monitored environments.

In case of a data breach, we follow specific protocols:

• Third parties are contractually obligated to inform us immediately of any data breaches.

• If a breach affects individuals' rights and freedoms, we inform you promptly and take necessary steps to address the issue.

• We record and report the breach, and the ICO is notified within 72 hours.

The handling of data breaches is managed by Walter Everett's directors.

 

How Long Do We Keep Your Data?

The duration for which we retain your data can vary. If we place you, we like to stay in touch to track your progress. We have a legal obligation to keep recruitment records for at least 1 year from our last service provided to a client.

We are not legally required to keep your details if we don't actively work to find you a job, and we may delete your record if consent is removed, if your skills don't match client requirements, or if consent was not given during our interactions with you. If we place you, we keep some of your data for 6 years for HMRC legal accounting and tax purposes.

Your Legal Rights to the Data We Handle

You have various rights concerning your data:

• The right to access your data and understand how we process it.

• The right to be forgotten and have your data deleted.

• The right to ask us to restrict your data.

• The right to port your data to another organization.

• The right to object to us handling your data.

• The right to withdraw previously given consent.

 

You can also lodge complaints regarding how we handle your data. We encourage you to contact us to exercise your legal rights. It's important to note that you may be required to pay fees associated with these rights. We might need to request certain information from you to verify and process your data.

We aim to respond to any requests within 1 month.

 

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