Colmore Recruitment is committed to protecting the privacy of our candidates, clients and users of our website and services. This policy sets out what personal data we collect from you and how we process and protect that data when you use our website or services. We will only use your personal data in accordance with the terms of this statement.
Any usage below of ‘we’, ‘us’ or ‘our’ is a reference to Colmore Recruitment Ltd and 1 Victoria Square, Birmingham, B1 1BD.
The General Data Protection Regulation (GDPR) will be applicable law in the UK from the 25th of May 2018. Your new rights in accordance with GDPR are included in this policy but will only apply once the GDPR comes into effect on the 25th of May.
Personal information we may gather from you
As a recruitment business we must process personal data (including sensitive personal data) in order to provide recruitment services to our clients and candidates. In doing so, we act as a data controller.
You may give your personal details to us directly, such as on a CV, an application or registration form, via our website or by corresponding with us by phone, email or otherwise. Personal data that we may collect includes:
Please note however, that this list is not exhaustive.
Depending on the nature of the role that you have applied for or that we have offered you, we may need to collect personal sensitive data. Under the General Data Protection Regulation this includes information about your health (for example details concerning any sick leave you may have taken during previous roles), information about any disability and details of any offences you may have committed or are alleged to have committed.
Personal information from other sources
We may also collect your personal information from another source such as a jobs board, personal recommendations or LinkedIn.
Do you have to provide us with personal data?
You may refuse to give us your personal and sensitive personal data. You also have the right to ask us to delete, change or stop processing your data that we already have (see below in what circumstances). If you do not provide us with personal or sensitive personal data however, it may restrict our ability to provide you with the recruitment and other related services that you have requested.
Purpose of processing and legal basis
We will collect your personal data (which may include sensitive personal data) and process that data for the following purposes:
To provide you with work-finding services to facilitate the recruitment process;
to assess your suitability for a position;
to tailor resources and services according to your preferences;
to maintain our business relationship, where you are a candidate, client or a user of our website;
to perform administration and operational functions.
Colmore Recruitment must have a legal basis for processing your personal data. The legal bases we rely upon to pursue our processing purposes are:
Our legitimate interests in providing you with our services. Such interests can however, be overridden by your privacy interests; legal obligation in some cases, where it is necessary for us to meet our legal or regulatory responsibilities; your consent to data processing for the activities not covered by our legitimate interests, which we will obtain from you from time to time.
An example of a situation where we would rely on consent is when we ask for permission to introduce you to a client; contractual obligations to which you are subject. This includes situations where we are negotiating or have entered into a placement agreement with you or any other contract to provide services to you.
Where Colmore Recruitment has relied on a legitimate interest to process your personal data our legitimate interests is as follows:
To offer you the tailored and efficient recruitment service you expect of us.
As a recruitment business, we introduce candidates to clients for permanent and temporary employment as well as offering clients’ vacancies to candidates. In order to do so, the exchange of personal data of our clients and candidates is essential to our operation. In order to support our candidates’ ambitions and to assist our clients with their resourcing needs, we also require to keep a database of client and candidate personal data. Furthermore, to maintain, expand and develop our business we need to record the data of prospective candidates and client data.
We want to offer you a tailored service that is customised based on the information that you provide us with. We also want to offer an efficient service, which means that we need to use your data for payroll and other administrative activities.
As a recruitment business, we may disclose your information to third parties where appropriate. Colmore Recruitment may share your information with the following third parties:
Our clients, in other words, prospective employers.
Payment intermediaries such as an umbrella company.
Pre-employment screening companies.
Government and law enforcement authorities.
Outsourced IT and document storage providers, for example servers and cloud-based data storage services.
Third party service providers, such as lawyers, accountants and technical support.
Any third party that we may share your data with must ensure the security of that data. Third parties are also obliged to only use your information for the purposes we have outlined. We will not pass on sensitive data to third parties without your consent, unless we are legally required to do so.
Colmore Recruitment may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
How long we store your information
Colmore Recruitment will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Where we have obtained your consent to process your personal and sensitive personal data, we will keep your data for 2 years after the last meaningful contact with you. Upon expiry of that period we will seek further consent from you. If consent is not granted, we will delete the personal data that we hold on you.
Please be aware that you have the following data protection rights:
The right to be informed about the personal data we process on you;
The right of access to the personal data we process 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 us processing your personal and sensitive data you have the right to withdraw that consent at any time by contacting our data protection officer (see below).
Complaints or queries
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.