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Privacy Policy for Access Appointments Consultancy Limited

Access Appointments Consultancy Limited (“the Company”) is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.

Collection and use of personal data
a. Purpose of processing and legal basis

The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.

In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

The legal bases we rely upon to offer these services to you are:
• Your consent
• Where we have a legitimate interest
• To comply with a legal obligation that we have
• To fulfil a contractual obligation that we have with you

b. Legitimate interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
• Managing our database and keeping work-seeker records up to date;
• Contacting the individual to seek your consent where we need it;
• Providing work-finding services to the individual, including sending their information to our clients where they have demonstrated an interest in doing that particular type of work but not expressly consented to us passing on their cv; and
• Contacting the individual with information about similar products or services that they have used from us recently

c. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
• Clients that we introduce or supply individuals to
• Candidates’ former or prospective new employers that we obtain or provide references to
• Any other third parties who carry out audits to ensure that we run our business correctly
• Payroll service providers who manage our payroll on our behalf
• Other recruitment agencies in the supply chain (e.g. master/neutral vendors and second tier suppliers);
• Our insurers
• Our legal advisers
• Our IT and CRM providers
• Any public information sources and third party organisations that we may use to carry out suitability checks on work-seekers
• Government, law enforcement agencies and other regulators; and
• Any other organisations an individual asks us to share their data with.

d. Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data may cause us not be able to introduce or supply work seekers to our clients.

Overseas Transfers
The Company 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.

Data retention
The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also 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 the Company has obtained your consent to process your personal and sensitive personal data, we will retain your data for no more than 10 years. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal and sensitive personal data.

Your rights
Please be aware that you have the following data protection rights, as set out in the General Data Protection Regulations GDPR (EU):
• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes 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 the Company processing your personal and sensitive personal data you have the right to withdraw that consent at any time by contacting Access Appointments Consultancy Limited, No 1 Royal Exchange Avenue, London, EC3V 3LT.

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

Website Privacy policy
The Company will collect the personal details that you provide to us on our website for the purposes of providing you with services and/or information.

Information Collection and Use
The Company collects information from our users at several different points on our website. The Company is the sole owner of the information collected on this site. We will not sell, share, or rent this information to others.

Registration
We request information from you on our online registration forms. Here you must provide contact information and information regarding the type of work you are seeking and your skills, qualifications and experience. This information is used to enable us to provide you with work-finding services. If we have trouble processing your application, this contact information is used to get in touch with you. The Company does not use this information for any other purpose.

Cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Log Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Sharing
We may share aggregated demographic information with our clients. This is not linked to any personal information that can identify any individual person.

Links
This website contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. We encourage you to be aware of this when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.

Security
The Company takes every precaution to protect our users’ information and are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, the company has put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we hold against manipulation, loss, destruction, and access by third parties. Our security measures are continually improved in line with technological developments.

Only employees who need the information to perform a specific job are granted access to your information.

The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Access Appointments Consultancy Limited, No 1 Royal Exchange Avenue, London, EC3V 3LT.
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.

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