Privacy Policy

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Our website and online services are designed to protect all users’ privacy in accordance with the Data Protection Legislation and General Data Protection Regulation (GDPR). The data you supply us with is fairly and lawfully processed. The following policy governs how we process the data you provide us with, in all forms. By using our website and registering your details with us, you consent to us collecting and processing your personal data. In connection with the recruitment process, this includes disclosing your data to prospective employers and clients.

Introduction

We are obliged to use your information in line with all applicable laws. We always do this in a fair way, ensuring your information is used as you would reasonably expect it to be to support the recruitment process. We are transparent about how your data is used.

This privacy policy outlines:

• The types of personal data we collect about you
• How and why we use it
• How long we will keep it for
• When, why and who we will share it with
• The legal basis on which we use your personal data
• Your rights in relation to us storing / processing your personal data
• How we may contact you, and how you can contact us

Part of the recruitment process involves sharing your personal data with our clients (independent data controllers) who have potential work opportunities that may be suitable to you. These third parties have their own privacy policies and also need to comply with applicable laws. We encourage you to contact them directly if you have any concerns or questions about your data.

Who we are

HCL International Limited is a managing consultancy. We provide consultancy services to clients seeking personnel for their business. We also help place candidates in roles.

What’s your legal basis for processing my data?

For prospective candidates, contractors, referees and clients, processing is necessary for our legitimate interests. This means we need your information to assess your suitability for potential roles, to find potential candidates or to contact clients / referees.

Our legitimate interests don’t override your interests or rights. We take into consideration the reasonable expectations of those actively applying for jobs, or making their personal information publicly accessible on professional networking sites.

If we submit you as a candidate, or you are requested for interview, this may involve processing more detailed personal data. This might include sensitive data such as health information or any information on unspent criminal convictions (either provided by you or others). Of course, if required to do this, we will ask your consent before processing it.

We may also need to process client information, if it involves fulfilling contracted requirements (for example, contacting you).

What Information do we collect?

We only collect and process personal data necessary for managing the recruitment process. This helps us match candidates to suitable opportunities. Throughout different stages of the recruitment process, we may need additional information in order to assess your eligibility.

The information we collect might include your name, email address, telephone number, CV, identification / right to work documents, educational records, work history, employment and references.

In general, we don’t ask for more sensitive personal data. However, there may be times when additional information is necessary, and for us to share that with potential employers. In these cases, we will only share information with your explicit consent.

In line with our client obligations, assessment includes asking you about any unspent criminal convictions you might have. We consider this highly confidential information and will only share this information with your explicit consent.

How do you collect my information?

We collect data on you from the following sources:

• Directly from you; via our registration process, information requests or applications via our website
• An agent or third party acting on your behalf; where you are consulting via a Limited Company
• Publicly available sources; professional networking sites or job boards where you have actively published / submitted your information
• Reference or word of mouth; recommendations by friends, former employers or colleagues

How do you use my information?

We only use your information to support the recruitment process. This includes, but is not limited to:

• Matching you with a role that suits your skills, experience and education (we use     technology to help identify the most suitable candidates for a specific role, but this does not constitute automated decision-making)
• Making you aware of current opportunities that may suit your requirements
• Contacting / updating you about your application, or roles you have been submitted for
• Sharing your details with clients to help secure a role for you (in this context, ‘client’ refers to the company you will work for, or an intermediary company that directly supplies the company you will work for)

If selected for interview or the next stage of the recruitment process, we will need further information. This is likely to come directly from you. However, it may also come from third parties, such as a referee.

Finally, we may also analyse data internally to help us offer amore relevant service. This could involve using your data for marketing and strategic development purposes, or to improve our offering.

How and when will you contact me?

We may contact you by phone, email or social media. Some examples of when we will contact you are:

• To     notify you if you are added to our database (after receiving your     information)
• When     one of our consultants considers you for a suitable job opportunity
• To     find out more about the type of roles you’re seeking
• Before     we put you forward for a role
• During     / following an assignment we have placed you in
• In     relation to any correspondence we receive from you
• To     update you on any material changes to our policies and practices

Who do you share my information with?

In order to manage the recruitment process, it’s necessary for us to share some of your personal data with clients who have potential work opportunities that might be suitable for you. Once we share your personal data, they will determine how to use, store and process it. As independent data controllers, our clients have their own privacy policies.

There may be circumstances where disclosure is required or permitted by law (such as to government or law enforcement bodies). For instance, for all candidates we place we are obligated to report pay details to HMRC.

We generally process your information internally at HCL international There may be occasions when we use third parties to process your information on our behalf. In these cases, third parties are under our strict instructions. They aren’t permitted to use your data for their own business purposes.

Will you transfer my data outside the EEA?

HCL international is based in the UK. In general, we don’t transfer your data outside the EEA. If we need to make transfers to countries beyond the EEA, we ensure appropriate safeguards are in place.

How long do you keep my personal data?

HCL international only retains information for as long as necessary for the relevant activity. This may be determined by legislation, or a decision as to what is necessary for the business. This is based on a number of factors.

If you have not registered with us, your data will be retained for 12 months after it is added to our database (or from when you were last contacted). You can request to have your information deleted at any time (see below).

If you register with us, your data will be retained for three years from the date of last contact, or recorded activity. Once again, you can request to have your record deleted at any time (see below).

If we place you in a temporary or permanent role, we are required to keep certain information for specific lengths of time, up to a maximum of six years. This is to comply with our legal obligations.

Client contact details are retained for three years and will be deleted upon request (see below).

Do you process special categories of personal data / criminal convictions?

We avoid processing special categories of data. Special categories of data refers to sensitive personal information such as race /ethnic origin, political opinions, religious / philosophical beliefs, trade union memberships, genetic data, biometric data, health data or information concerning a person’s sex life or sexual orientation.

Nevertheless, by taking copies of passports or ID, it may be that racial or ethnic origin is revealed. Processing this data is necessary for us to comply with employment law. However, rest assured that data is only used for this specific purpose.

One of our obligations is to ensure candidates we submit to clients are suitable for the given role. As part of our registration process, we require individuals to disclose any unspent convictions. If necessary, we may need to make further enquiries.

Will you contact me for marketing purposes?

We only send direct marketing emails promoting our company or services if you have opted-in for this. You can choose to opt-in when you receive a copy of our privacy policy. You can also manage direct marketing preferences by contacting us, updating your preferences, or by clicking the ‘unsubscribe’ link in one of our emails. For clarity, contacting you about specific job opportunities is not marketing.

Can I refuse to provide my data, or request that you delete it?

You have the right not to provide us with any personal data we request from you, or to withdraw your consent from our using it. However, this means we may not be able to match you with available job opportunities.

You also have the right to object to us processing your databased on legitimate interest. If you have not been placed in a role, we will be able to delete your data. You have the option to delete your data when provided with a copy of our privacy policy.

If you have been successfully placed, we are under certain legal obligations to retain information for specified periods (up to six years). This includes ensuring you have the right to work in the UK, and allowing us to comply with HMRC reporting requirements. In such situations, we are legally obligated to continue processing your data.

However, you do have the right to restrict processing of your data. This means we will stop further use of it, but still store it. However, please be aware that if we stop processing your data, any assignment you are currently be working on will be terminated immediately, or in line with any notice period.

Please also note that we may require proof of your identity /answers to security questions before processing your data request. If your data is deleted, we will have no record of this and so you may be contacted again in the future.

How do I find out what data you hold about me?

You have the right to access a copy of your personal data. If any of the data we hold is inaccurate, you can ask us to correct it.

To exercise your right to access your data, please make a written subject access request. Please include proof of your identity. We will also need you to answer security questions before processing your request.

We usually act on such requests and provide information free of charge. Under exceptional circumstances, we may charge a reasonable fee to cover our administrative costs for:

• Baseless     or excessive / repeated requests
• Further     copies of the same information

Alternatively, we may have the right to refuse to act on these requests. Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this is within a month of receipt. However, if for any reason we expect it to take longer, we will let you know.

Do I have the right to data portability?

The GDPR introduces a new right to data portability. This enables individuals to receive and transmit their personal information between two data controllers, in a structured, commonly used and machine-readable format. The right to data portability only applies to the following:

• Personal data provided directly by you
• Personal data processed with your consent, or on the basis of a contract (excluding the other legal bases)
• When     processing is carried out through automated means

As we rely on the legal basis of legitimate interests, this right doesn’t apply to data we hold about you. In addition, references obtained directly from third parties about you are not subject to the right of data portability.

Changes to this privacy policy

We reserve the right to change our privacy policy at any time. Changes will be displayed on our website.

Complaints

If you have any questions or concerns, please write to us.

If you feel we haven’t dealt with your complaint satisfactorily, you can complain to the ICO, the UK’s supervisory authority. You also have the right to claim compensation for damages caused by a breach of data protection legislation.

 

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