Three Sixty Selection Ltd (”We”) are committed to protecting and respecting your privacy.
threesixty and threesixty selection are trading names of Three Sixty Selection Ltd.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
For the purposes of data protection legislation the data controller is Three Sixty Selection Ltd, Arden Hall, 66 Brooklands Rd, Sale, Manchester, M33 3SJ.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Who we are and what we do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We collect the personal data of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent, interim or temporary roles;
- B2B client contacts – both Prospective and Live;
- Supplier contacts – past, current and potential future suppliers of services to support our business.
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you
This is information about you that you give us by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
The information you give us or we collect about you will include information that is typically held in a curriculum vitae (CV) and may include your name, address, post code, private and corporate e-mail address, phone number and other contact details, employment history, qualifications, skills, experience, interests, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, employment preferences, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter or via other Social Media or a corporate website. It may also include, but is not limited to; age, nationality, gender, compensation details, reporting lines, team sizes, a record of our contact history with you, views and comments and/or references from third parties.
Information we collect about you when you visit our website
With regard to each of your visits to our site we will automatically collect the following information:
Technical and Analytical information relating to your visit including; IP addresses, browser details and system details. Visit information – including; page views, page response times, download errors, length of visit, clickstream and page exit information.
Information we obtain from other sources
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations and any relevant social media sites. In this case we will inform you, by sending you an email, within a maximum of 30 days of collecting the data, of the fact we hold personal data about you.
We may also receive information from third parties we work closely with for the purposes of providing our recruitment services and ancillary support services, including; business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers and professional advisors.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Your personal information may be used in an anonymised form i.e. summary information may be shared with a client to illustrate a particular profile (used in this manner, it will not be possible to identify the data subject). We will always contact you and obtain your consent before presenting further details and/or indicating any potential interest you may have in an opportunity.
We may share your personal information with third parties where we have retained them to provide services that you or our clients have requested, such as referencing, qualification and criminal reference checking services (as required and subject to consent), verification of the details you have provided from third party sources, psychometric evaluations or skills tests. We may also share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems and function co-ordinators. These third parties are also required to comply with the obligations of the GDPR and will have similar and equally stringent undertakings of privacy and confidentiality.
Our legal basis for the processing of personal data is for our legitimate business interests, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
To deliver our services we need to contact candidates on a regular basis, through various routes such as email, phone, job alerts and other relevant notifications.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
- Use of our website;
- To notify you about changes to our service;
- To ensure that content from our site is presented in the most effective manner for you and for your computer;
We will use this information:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- To allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our site safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process. We do not undertake automated decision making or profiling.
Disclosure of your information inside and outside of the EEA
We will share your personal information with selected third parties including:
- clients for the purpose of introducing candidates to them;
- candidates for the purpose of arranging interviews and engagements;
- clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
The lawful basis for the third party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
- satisfaction of their contractual obligations to us as our data processor;
- for the purpose of a contract in place or in contemplation;
- to fulfil their legal obligations.
Where we store and process your personal data
The data that we collect from you will be transferred to, and stored at, our IT hosting partner, Access UK Ltd (www.theaccessgroup.com) who provide us with an integrated suite of software that includes a Customer Relationship Management (CRM) database, email services and other packages that we use in the process of our legitimate business interests. Access UK Ltd provide a robust Information Security Management System that has been certified to ISO27001:2013 by Alcumus ISOQAR, a UKAS accredited certification body. By submitting your personal data, you agree to this transfer, storing or processing.
Three Sixty Selection Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice. We use reasonable efforts to ensure that data is accurate, current and reliable for its intended use. We use a variety of measures and safeguards to help protect your personal data from unauthorised access, misuse, alteration or loss, which will include but is not limited to: Locking away of confidential material and IT equipment, secure offices and password access to hardware and systems.
Our internal policies are designed to help ensure we safeguard the privacy and accuracy of all data we collect or process. To the extent that we disclose personal data to clients or third parties, we request that they properly protect the security and confidentiality of such information and otherwise process such data in accordance with applicable law.
Our employees undergo training on data privacy and security and are required to comply with our internal standards in these areas.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.
We do the following to try to ensure our data is accurate:
Prior to making an introduction we check that we have accurate information about you and we keep in touch with you so you can let us know of changes to your personal data.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system.
Our current retention notice is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights. To:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain formats, if practicable.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
A subject access request should be submitted to our Data Protection Officer via firstname.lastname@example.org or in writing at the business address below.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Data Protection Officer, threesixty selection ltd, Arden Hall, 66 Brooklands Rd, Sale, Manchester, M33 3SJ.