GDPR Policy
PRIVACY POLICY
MRJ Recruitment Ltd (MRJ) are committed to protecting and respecting your privacy.
This notice together with our Data Protection Policy 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.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Our nominated Data Protection representative is Grant Spencer and can be contacted at DPO@mrjrecruitment.com
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 or temporary roles
- Prospective and live client contacts
- Supplier contacts to support our services
- Employees, consultants, temporary workers
We collect information about you to carry out our core business and ancillary activities.
1. Information you give to us or we collect about you
This is information about you that you give us by filling in forms on our site www.mrjrecruitment.com (our site) or 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, apply to a vacancy, 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 may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Your personal data will be stored on our servers and specifically in our CRM system Daisyblue. Your data can only be accessed by our employees and thus are obliged to comply with GDPR when processing your personal data, provided you reside in the European Union.
Your personal data may also be shared with our clients for the purpose of introducing you or arranging interviews with them, upon prior written notice to you in which one of our staff members outlines which client(s) MRJ will share your details with and the exact data that will be forwarded to this client. Our employees will only share your personal data with our clients if you explicitly agree for them to do so.
We may furthermore disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we will have to disclose your personal data to the prospective seller or buyer of such business or assets. Furthermore, we may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to defend our business against a legal claim or in order to enforce or apply our standard terms of business or other agreements or to protect the rights, property or safety of MRJ, our customers, or other parties.
2. Which personal data MRJ collects
MRJ only collects personal data to help us match you with the right career opportunity and would typically collect the following personal data:
- Your full name
- Your registered address
- Your date of birth
- Your email addresses
- Your (mobile) telephone number
- Your website
- Professional profiles available in the public domain, e.g. LinkedIn, Twitter or Facebook
- Your CV
- Skillset (if not already covered in a CV)
- Job preferences (if not already covered in a CV)
- Current employer/client
- Your passport/visa, when requested by the client
- Current salary/employment conditions
- Desired salary/ employment conditions
- Other documentation, if requested by our clients (e.g. references)
3. How MRJ collects personal data
MRJ collects your personal data in the following ways:
You apply for a job in response to a job advert via mrjrecruitment.com or on an external job board, e.g. Indeed, CWJOBS or LinkedIn, etc.
You upload your CV on mrjrecruitment.com
You complete a ‘Contact us’ form or register with MRJ on our website
A MRJ Recruitment Consultant gets in contact with you because they found your profile on a database/ job board you have subscribed to or registered your CV with and MRJ uses these platforms to headhunt and access details of candidates
We have received your details about you from another third party, for instance; a business contact, a client or professional advisors
You have met or spoken with a MRJ Recruitment Consultant and are sharing information or sending your CV/application by email to MRJ
When MRJ receives your details in one of the above ways we save your application and information provided by you on our CRM system. Your information and application will be reviewed by our consultants who will potentially share that information with our clients to advance your application, provided you have given your express consent to this upfront.
When we receive these details, our consultants will inform you as soon as possible of collecting the data of the source where your personal data originates from. If this information is not provided, please let us know straight away and we will confirm how we located your data.
4. Why we hold your data and legal basis
MRJ will collect your information to carry out our core business and ancillary activities – for the purpose of recruitment services. In particular, MRJ will collect and process your personal data for the following purposes:
- Introducing you to (potential) clients or employers of which the scope will be identified and communicated by one of our members of staff;
- Keeping your personal data on file for current and future opportunities that may arise;
- Evaluating your experience with MRJ and our recruitment process;
- If we ask for a copy of your passport or visa, we do this as we may have to verify your identity and/ or the right to work.
- Clients may ask MRJ to provide them with additional documentation (e.g. your passport details, Payslips or references). If that happens we will ask for your permission to share these data with our clients. Please let us know if you have any issues with this.
5. The following legal basis applies for processing your data if we have been in touch with you within the last three years:
- We will process your data as we believe that we have legitimate interests to do so.
- We have carried out a three-part test (a so-called legitimate interest’s assessment).
- As a recruitment business, we introduce candidates to clients for permanent employment and temporary worker placements (if you provide services as a contractor through MRJ). The exchange of relevant personal data of our candidates to our client contacts is paramount if we want to provide services to our clients or support our candidate’s career aspirations.
- As we thus need to satisfy our client’s resourcing needs we require an up-to-date database of candidate data. We would only use your personal data to introduce you to our clients and do not share more data with our clients than reasonably necessary. We would usually only process data that is already available online to other recruiters (e.g. a CV downloaded from a job board). We always ask for your permission before we process any of your sensitive data (e.g. passport copy or references). In practice, we would acquire this type of information only upon request when we introduce you to one of our clients.
- Thus, to maintain, expand and develop our business we need to record the personal data of our (prospective) candidates who have been in touch with MRJ within the last three years. We have chosen this three-year period as it is likely that (1) there is a(n) ongoing relationship between you and MRJ (2) you may be looking for opportunities that MRJ can help you with and (3) your data on our database is still up-to-date. We have also chosen this three-year period as we think this timeframe is regarded to be industry standard.
6. The following legal basis applies for processing your data if we have not been in touch with you within the last three years:
If you have not been in touch with us for the last three years, we understand that the data (1) we hold on file may be inaccurate (2) you may not be interested in getting contacted by MRJ anymore.
We will, therefore, process your personal data only if you have given your consent for us to do so. We will request your consent by an online process for the specific activity we require consent for and record your response on the system. If you haven’t already done so, to opt in any email communications from us, please click the ‘subscribe’ link.
You are entitled to withdraw consent or restrict the use of your personal information for whatever purpose at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
To opt out of any data processing and/ or email communications from us, please click the ‘unsubscribe’ link at the foot of the email in question for an immediate removal from our database and /or further communications.
Furthermore, if you previously agreed to us holding or using your personal information, you may change your mind at any time by accessing the preference centre to change your settings. Alternatively, you can email dpo@mrjrecruitment.com. We will process the restriction of use in our marketing communications or removal of your personal information within 30 working days.
7. The following legal basis applies for processing your data if you are (permanently) employed by one of our clients:
If you are a candidate of MRJ and have been successfully hired by one of our clients, we have a legal obligation to keep your data on file for six years. This legal requirement is in place so that MRJ is able to evidence any transactions with our clients for tax purposes and to be able to produce proof of the placement should any legal claims arise against MRJ by any parties involved during the recruitment and/or hiring process.
8. How long will we store your data?
Your personal data will be stored in our systems for three consecutive years. As long as you are working with MRJ’s Recruitment Consultants on your next career step, we will keep your data on file to be able to match you with the latest opportunities and to contact you.
Your data will be removed from our systems if:
- We have not heard from you during a period of three years, or
- If you request for your data to be removed
Different retention periods apply if
- you have entered into an agreement with MRJ for which a different Data Processing Notice applies (see for example Privacy Policy for Contractors below) or
- unless there is a direct statutory requirement (that comes into force) under which MRJ is obliged to keep your data stored in our internal databases for another period of time. This applies for example if you are hired by one of our clients and MRJ subsequently needs to keep records to the relevant transaction.
9. What are your rights under GDPR
Under GDPR you are entitled to various rights:
- You can 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. This means when working with our Recruitment consultants, make sure you notify us of any changes or update your information like email, phone number etc. when they change.
- You can 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). This means should you wish to be removed from MRJ’s database, please email dpo@mrjrecruitment.com We will review and process your request within 30 days.
- You can object to the 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.
- You can 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.
- You can request the transfer of your personal information to another party in certain formats, if practicable.
- MRJ will, however, provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of the request, however where requests are manifestly unfounded or excessive, in particular, because of its repetitive character, MRJ may refuse to act upon your request. In that case, we will inform you within one month of the request of the possibility of lodging a complaint with a supervisory authority (in the UK this will be the ICO) or seeking a judicial remedy.
9. Automated decision making, including profiling
MRJ will not conduct any forms of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, in particular, to analyze or predict aspects concerning your personal preferences, job roles interests, reliability, behavior, location or movements. We will not make decisions that are based solely on automated processing which produces legal effects, or similarly significantly affects you as a data subject.
10. Lodging a complaint
If you feel that your rights as a data subject have been breached, you are entitled to lodge a complaint with the national supervisory authority (in the UK this will be the Information Commissioner’s Office via https://ico.org.uk/concerns/) or seek a legal remedy. However, we strongly encourage you to contact us via DPO@mrjrecruitment.com
11. Changes to this Data Processing Notice
Any changes we make to our Data Processing Notice in the future will be posted on this website and where appropriate (if we make any significant changes that may affect your rights as a data subject), notified to you by email. Please check back frequently to see any updates or changes to this Data Processing Notice.