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                                                                      Privacy Policy


C.K.R. Agency Ltd – T/A Cameron Kennedy (”We”) are committed to protecting and respecting your privacy.

Our Group means our subsidiaries, our ultimate holding company and any subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).

This notice together with our terms of use Terms and Conditions sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers, and other people whom we may contact in order to find out more about our Candidates or whom they indicate is an emergency contact. We take our obligations in respect of privacy of personal information very seriously and we will only process personal information as detailed in this policy unless we inform you otherwise. In order to ensure that the personal information is accurate and up-to-date, we request that you inform us of any relevant changes to personal information we hold about you.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a regulation in force from May 25th 2018, replacing 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 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. 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.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection legislation in force from time to time the data controller is C.K.R. Agency Ltd – T/A Cameron Kennedy, 20 Chiswell Street, London, EC1Y 4TW.

The person responsible for data protection matters within our organisation is Sheldon Paule. He can be contacted at datarep@cameronkennedy.com

If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us,  Please refer to Section 4 ’Your rights‘, in respect of data that we already hold, or which we receive from third parties.

 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:

- Candidates including prospective and placed candidates for permanent, contract or temporary roles;
- Actual or potential hiring contacts, clients and customers;
- Supplier contacts to support our services and business;
- Employees, consultants, temporary workers.

We collect information about you to carry out our core business and ancillary activities.

We do not collect your personal data for the purposes of selling personal data to third parties.

SECTION 1: This section applies to individuals using our Recruitment Services ('a Candidate')

Information you give to us or we collect about you.

The information you give us or we collect about you may include:

- Your name;
​- Your address;
- Private and corporate e-mail address and phone number:
- Financial information such as bank details for payment purposes;
- Details about your current remuneration, pension and benefit arrangements; 
- Social security number, national insurance number and tax (payroll) information; 
- Copy of your passport/identity card/driving licence; 
- Compliance documentation and reference details; 
- Your qualifications and experience; 
- Your immigration status and/or right to work in the United Kingdom;
- Nationality/citizenship/place of birth;
- Date of birth;
- Sex/gender for diversity purposes;
- Emergency contacts;
- Job title;
- Current  employer;
- Employment  history;
- Education details;
- Curriculum vitae and photograph;
- Links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website;
- Other diversity information;
- Personal information on your interests, pastimes or hobbies;
​- Needs regarding future employment both collected or inferred for example from jobs viewed or articles read on our website;
- Extra information that your referees choose to tell us about you;
- Extra information that our Clients may tell us about you or we find from other third party sources such as job sites;
- Emergency contacts
​- Your marketing preferences;
- IP address;
- Dates times and frequency of which you access our services; and
- CCTV footage if you attend our premises.

Sensitive Personal Data 

​Sensitive personal data is defined as information which is intensely personal information to you. As a matter of course, it is not information we view as relevant when considering your suitability for a role. Sensitive personal information could include your religious, political or philosophical beliefs, sexual orientation, race or ethnic origin or health information. We request that you do not supply us with sensitive personal information unless it is essential. However if you do provide us with sensitive personal information, including sensitive personal information passed to us during conversation, we shall only use that data  for the purposes of our relationship with you or the provision of recruitment activities. This will be for one or more of the following reasons:
​- To assess your suitability for job roles or working capacity;
​- You have explicitly consented to the processing;
​- To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims;
​- Where processing is necessary for the purposes of obligations or rights under employment, social security or social protection law.

How we may obtain your personal data

We may obtain information about you in the following ways: 

- From you ( e.g. a curriculum vitae, application, registration, a form on our website, entering our database, asking us to find you a job or asking us to fill a vacancy, contacting us by email, post or telephone call, subscribing to our services, attending our events, when you report a problem with our website);
- A client;
​- Other candidates;
​- Online jobsites;
​- Marketing databases;
- The public domain;
- Social media including participation in discussion boards;
- At interview;
- Corresponding with us by e-mail or in writing;
​- Conversation on the telephone or video conferencing;
​- Notes following a conversation or meeting;
- Entering a competition, promotion or survey;
​- Our website or software applications;
Please note the above list is not exhaustive.

If we obtain your personal data from a third party

Part of our business activity involves researching information for the purposes of finding and filling job roles. This is information we obtain about you from other sources such as LinkedIn, corporate websites, job boards, online CV libraries, advertisements, other social media, your business card, (if not provided personally by you), personal recommendations, third party outsourced research entities, list brokers and some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal data about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged. In this case we will inform you, by sending you a privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors.

Where information from third party sources is of no use to us we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Recruitment Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 'Your rights'.

How we will use your personal data

The processing of your personal information may include:

​- Collecting and storing your personal data, whether in manual or electronic file;
​- Notifying you of potential roles or opportunities;
​- Assessing and reviewing your suitability for roles;
- Assessing and reviewing your information in relation to ancillary services such as career or salary advice;
​- Introducing and/or supplying you to actual or potential Clients;
​- Engaging you for a role with us or with our Clients, including any related administration e.g. timesheets and payroll;
​- Collating market or sector specific information and providing the same to our clients;
​- Sending information to third parties with whom we have or intend to enter into arrangements which are related to our recruitment activities;​
- Providing information to statutory bodies or regulatory authorities, and our legal or other professional advisers including insurers;
​- To market our recruitment services and activities;
​- Retaining a record of our dealing;
​- Establishing quality, training and compliance with our obligations and best practice;
​- For the purposes of backing up information on our computer systems.

Why we process your personal data

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 services or goods 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, fixed term or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.

- Our legal basis for the processing of personal data includes legitimate interest, described in more detail below, 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 (regulatory and statutory obligations). We must comply with a number of statutory provisions when providing our recruitment activities, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things require us to verify your identity, assess your suitability for an external job role or roles and maintain records for specific periods including retaining your data for a minimum of one year. We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities such as HMRC or the Information Commissioners' Office.

- 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 interests (carrying on the commercial activities of a Recruitment business)

Article 6(1)(f) of the GDPR  says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data." You do have the right to object to us processing your personal data on this basis. We, however, don't have any reason to think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, effective and efficient services. Our legitimate interests in collecting and retaining your personal data are:

- As a recruitment business and recruitment agency we are engaged in various recruitment activities including introducing 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  and 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. This also includes sourcing potential opportunities or roles as part of our recruitment activities.

- To maintain, expand and develop our business, we need to record the personal data of candidates and client contacts including prospective candidates and client contacts. In order to offer candidates to our clients, we need to be able to conduct adequate research to identify suitable candidates which often relies on detailed knowledge of a candidate’s skill set, qualification and/or work history based on the data we collect, process and hold. In order to approach candidates with regards to our advertised,  unadvertised or potential vacancies, we need to be able to conduct adequate research to identify and assess suitable candidates, which often relies on detailed knowledge and understanding of a candidate’s skill set, qualification and/or work history based on the data we collect, process and hold. In order to expand our business and potential to offer a variety of vacancies and work finding services to candidates, we need to collect, process and hold details of actual or potential hiring contacts, clients and customers. In order to provide the best possible employment opportunities that are tailored to them. We need to process certain information about them. We only ask for details that will genuinely help us to help them.

- To deliver our ancillary services such as providing market information or trends including providng analysis to clients or potential clients which may include salary surveys to clients or potential clients, salary advice to individual candidate’s, company staffing mapping, industry surveys, we need to collect, process and hold detailed knowledge of different candidate’s skill set, qualification, job title, date of qualification, salary and/or work history. This is not an exhaustive list.

- Maintaining a back-up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or breach.

- Protecting our reputation.

Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:

- establishing compliance with contractual obligations with Clients or suppliers

- addressing any query or dispute that may arise

- evaluating quality and compliance including compliance with this Privacy Notice

- determining staff training and system requirements

- Using your personal data to:

- assess suitability and contact you regarding potential opportunities and/or our services

- source potential opportunities or roles as part of our Recruitment Services

- personalise your experience and our offering, whether via our website or otherwise

This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.

Our recruitment activities include:

- Collecting your data from you or other sources such as LinkedIn, Cameron Kennedy’s website or jobsites;
- Storing your details on our CRM database and also updating your details when necessary, so that we can contact you in relation to recruitment and work-finding services;
- To provide you with our recruitment services and to facilitate a recruitment process;
- Assessing your data against vacancies which we think you might be suitable for;
- Sending your information to clients in order to apply for jobs or to assess your eligibility;
- Enabling you to submit your CV, apply on-line for jobs or to subscribe to alerts about jobs we think might be of interest to you;
- Allowing you to participate in any evaluations or on-line assessments required by a client or third party (such as psychometric testing or skills tests);
- Allowing you to participate in any on-line training or briefing prior to interview;
- Allowing you to participate in any interactive services we may provide when you choose to do so;
- Carrying out our obligations arising from any contracts entered into between us or contract proposals between us;
- Carrying out any obligations arising between Cameron Kennedy and third parties in relation to a client’s recruitment process or your recruitment;
- Facilitating our payroll and invoicing processes;
- Carrying out customer or candidate satisfaction surveys;
- Requesting information (such as references, qualifications and potentially any credit checks and/or criminal convictions to the extent that this is appropriate and in accordance with local laws);
- Complying with Cameron Kennedy’s legal obligations in the connection of crime detection or the collection of taxes or duties;
- Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you in relation to work-finding services.

Marketing activities

We may from time to time send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate. Please note that this list is not exhaustive.

- Market our full range of recruitment services (permanent, temporary, contract, outplacement,) to you;
- Send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you; and
- Display on our website or marketing material a promotional testimonial which you have provided to us but only where we have obtained your express consent to do so.

We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft opt-in.

Soft opt-in

Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us and we are marketing other recruitment related services. Engagement can include submitting a job application or CV, or registering a vacancy to be filled, providing us with your telephone number or email address in order to receive details of vacancies. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to them alongside the specific one they applied for, significantly increasing the likelihood of us finding them a new position. For other types of e-marketing, we are required to obtain your explicit consent.

You have the right to withdraw your consent at any time and can find out more about how to do in the Consent area below.

Consent

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. We may process your personal data on the basis that you have consented to us doing so for a specific purpose such as applying for a role, in order to consider your application and consider your suitability. Where consent is the lawful basis for our processing your personal information you have the right to withdraw your consent to this particular processing at any time. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitImate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.

We will keep records of the opt-in consents that you give to us.

As described previously, we also will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services and activities we provide as long as you do not actively opt-out from these communications.

You have the right to withdraw your consent for either type of opt-in at any time by sending an email to: datarep@cameronkennedy.com with the word UNSUBSCRIBE in the subject or by clicking the unsubscribe link in any email you receive from us. We will unsubscribe you as soon as possible after receipt.

Who we share personal data with

We will share your personal information with:

- Any member of our group both in the EEA and outside of the EEA if they are travelling outside of the EEA.
- 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;
- Subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have applied to their advertisement on any given day).
- Credit reference agencies, insurers, legal and professional advisers, 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;
​- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us.
Parties who process data on our behalf which may include:
- Outsourced payroll providers
- If you visit our website, analytics and search engine providers that assist us in the improvement and optimisation of our website;
- IT support
- Storage service providers including cloud providers
- Background screening providers
- Mimecast, Sign-Up To; Survey Monkey; Eventbrite; MailChimp

Our service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements.

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.

Automated decisions

We may use software to review the personal data of individuals recorded on our database, or who have applied for specific roles. The software may determine suitability for a specific role via targeted questions relating to the role, and/or may identify and select individual personal information according to the stored characteristics. For example, the software may enable us to quickly identify individuals from our database who have specific skills, e.g. an engineer and exclude individuals whose characteristics do not match particular requirements of a job role. However, a person will always be involved in the decision-making process.

Where we use software to assist us with our assessment of your suitability for a particular job role and you consider that any such assessment has been made wrongly or incorrectly, you may ask for an explanation.  

SECTION 2: This section applies where you are an individual working for a third party with whom we have dealings. For example, a client.

Information you give to us or we collect about you.

We may collect your personal data in the course of our dealings and this may include the following:
- Your contact information, which may include your full name, job role, contact telephone number and email;
- Your statements and opinions about candidates and/or other personnel e.g. a reference;
- Information relating to our relationship with you or the party for whom you work including records of any meetings or discussions;
- Your marketing preferences;
- IP address if you access our website;
- dates times and frequency of which you access our services; and
- CCTV footage if you attend our premises.

How we may obtain your personal data

We may obtain your personal data from the following sources:
- From you, including where you have provided us with your contact details or other information for the purposes of using our Recruitment Services;
- Staff or other representatives of the organisation you represent;
- Marketing databases;
- Social media including participation in discussion boards;
- The public domain;
- Conversations, with you or others, on the telephone or video conferencing (which may be recorded) or in meetings
- Notes following a conversation, with you or others, or meetings you attend
- Entering a competition, promotion or survey;
​- Our website or software applications;
- CCTV footage if you attend our premises.
Please note the above list is not exhaustive.

How we will use your personal data

We will process your personal data in the context of our dealings with the third party for whom you work and as part of our Recruitment Services. Processing may include:
- Collecting and storing your personal data, whether in manual or electronic files;
- Using the data to communicate with you;
- Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services;
- Actions necessary to further any obligation on us pursuant to a contract between ourselves and the third party you work for;
- Collating market or sector specific information and providing the same to our clients;
- Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers;
- Retaining records of our dealings with you and the organisation whom you represent;
- Establishing quality, training and compliance with our obligations and best practice.
- Facilitating our payroll and invoicing processes if you are a contact in these processes;
- Carrying out customer satisfaction surveys;
- Requesting information (such as references);
- Complying with Cameron Kennedy’s legal obligations in the connection of crime detection or the collection of taxes or duties;

Why we process your personal data

Compliance with legal obligations (regulatory and statutory obligations):
We must comply with a number of statutory provisions when providing our Recruitment Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things requires us to assess suitability of candidates and obtain information from Clients. We are also required to comply with statutory and regulatory obligations relating to business generally, for example tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities such as HMRC.

Our legitimate interests (carrying on the commercial activity of Recruitment Services):
In providing our Recruitment Services, we will carry out some processing of personal data  which is necessary for the purpose of our legitimate interests, which include:

Using your personal data:
- to contact you regarding our Recruitment  Services;
- to assess suitability of Candidates and roles, for example, referencing or other feedback;
- to collate market information or trends including providing analysis to potential or actual Clients;
- as otherwise necessary to provide our Recruitment Services and/or to meet our obligations towards either the party whom you represent, or other Clients or suppliers;
- to personalise your experience and our offering, whether via our website or otherwise;

Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
- establishing compliance with contractual obligations with Clients or suppliers;
- addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
- protecting our reputation;
- maintaining a back-up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach;
- evaluating quality and compliance including compliance with this Privacy Notice;
- determining staff training and system requirements;

For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.

Consent

We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason, for example references.

You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations.  Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

If we obtain your personal data from a third party

Part of our business activity involves researching information for the purposes of finding and filling job roles. This is information we obtain about you from other sources such as LinkedIn, corporate websites, job boards, online CV libraries, advertisements, other social media, your business card, (if not provided personally by you), personal recommendations, third party outsourced research entities, list brokers and some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal data about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged. In this case we will inform you, by sending you a privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors.

Where information from third party sources is of no use to us we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Recruitment Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 'Your rights'.

Sensitive Personal Data

Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our dealings with you in respect of our Recruitment Services. Examples of Sensitive Personal Data include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health. Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that personal data for the purposes of our relationship with you or for the provision of our Recruitment Services. This will be for one or more of the following reasons:

- You have explicitly consented to the processing;
- Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law;
- To maintain records of our dealings to address any later dispute, including but not limited  to the establishment, exercise or defence of any legal claims.

Who we share personal data with

We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
- Any member of our group both in the EEA and outside of the EEA if they are travelling outside of the EEA;.
- Candidates and other third parties necessary for the provision of our Recruitment Services;
- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us;
 - Legal and professional advisers
- Insurers
Parties who process data on our behalf which may include:
- Outsourced payroll providers
- If you visit our website, analytics and search engine providers that assist us in the improvement and optimisation of our website;
- IT support
- Storage service providers including cloud providers
- Background screening providers
- Mimecast, Sign-Up To; Survey Monkey; Eventbrite; MailChimp

Our service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements.

SECTION 3: This section applies to all personal data

Transfer

We will disclose your personal information to third parties:

- In the event that we sell any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Cameron Kennedy or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use Terms and Conditions and other agreements; or to protect the rights, property, or safety of Cameron Kennedy, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie notice which can be found at https://www.cameronkennedy.com/cookie-policy? . 

Information we collect about you when you visit our website.

With regard to each of your visits to our website we will automatically collect the following information:

- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, operating system and/or platform;

- information about your visit, including your cookie preference when indicated, website page you visited for up to two hours after the last visit to that page, your unique actions on the website, the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), jobs or products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any telephone number used to call the offices of Cameron Kennedy.

Uses of your data in connection with our website:

- 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 website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our website 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 website 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 website about goods or services that may interest you or them.

Where we store and process your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties, for example Clients or Candidates, outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or third parties who provide support services to us such as a supplier. This includes staff engaged in, among other things, our recruitment services and the provision of support services. 

Where information is to be so transferred, it may be to a country in respect of which there is an adequacy decision from the EU Commission. However, if this is not the case, it is our policy to take steps to identify risks and in so far as is reasonably practicable, ensure that appropriate safeguards are in place. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us or you enter on our website is actually stored on our third party providers highly secure servers within the EAA.

Data security and confidentiality

It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice. We maintain administrative, technical and physical safeguards to protect against unauthorized disclosure, use, alteration or destruction of the Personal Information stored within our systems or website.

As regards you using the internet, 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 our website or to Cameron Kennedy itself; any transmission is at your own risk. However, once we have received your information, we  use strict procedures and security features to prevent as far as reasonably practicable unauthorised access.

Where we have given you or where you have chosen a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

If you do not wish to provide us with necessary data

There may be circumstances where we require you to provide data which is necessary in order for us to meet statutory or contractual obligations, or perform our Recruitment Services. If you do not wish to provide us with information we request then please notify us. However, please be aware that as a result we may be unable to provide you or the party who you represent with a Recruitment Service, and in some cases may result in a breach of the contract we have with you or a third party you represent.

Retention of your data

In most circumstances your data will not be retained for more than 6 years from the last point at which we provided any services or otherwise engaged with you and it is our policy to only store your personal  data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests.  However, we may retain data for longer than a 6 year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, for example where your personal information identifies specialist skill sets which may remain in demand, or we are subject to a legal obligation which applies for a longer period.  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. Accordingly, we have a data retention policy and run data routines to remove data that we no longer have a legitimate business interest in maintaining.

If however you believe that we should delete your personal data at an earlier date, please inform us of your reasons in writing or via email to our data representative: datarep@cameronkennedy.com.  Please see Section 4 ‘Your Rights’ 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.

SECTION 4: Your rights

We take the protection of your personal data very seriously and it is important that you know your rights within that context.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you if we intend to use your data for such purposes. We do not disclose your information to any third party for such purposes. We will collect express consent from you if legally required prior to using your personal data for marketing purposes. However, if you are a candidate, normally we will rely on a soft opt-in as previously described where we are providing recruitment services but you still have the right to ask us not to process your personal data for marketing purposes.

You can exercise your right to accept or prevent such certain types of communication from us by checking certain boxes on the forms we use to collect your data on our website if you are registering through our website. You can also exercise the right to withdraw or provide consent at any time by contacting Sheldon Paule at: datarep@cameronkennedy.com or by clicking unsubscribe on any email communication you receive from us.

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

- 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). We will respond to your request within 28 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data.
- 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. We will  either directly transfer your data for you, or provide you with a copy in a commonly used machine-readable format.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office (ICO). The ICO can be contacted through this link: https://ico.org.uk/concerns/.

Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third party source. If you would prefer us not to do this, you are free to say so.

You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations

Please note that we are required to retain records In order to demonstrate compliance with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 which require the retention of work-seeker records for at least one year after their creation and at least one year from the date we provided our services.

We are also required to comply with statutory and regulatory obligations relating to business generally and may be required to retain your personal data, for example required by tax, bribery and fraud/crime prevention legislation, and retention of personal data to comply with regulatory authorities such as HMRC.

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.
You have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information. Once having made contact with us, we may comply with your request or, additionally we may ask you to verify your identity, or ask for more information about your request.
Where we comply with your request we will respond without undue delay and in any event within one month of receipt of the request.
If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
If we determine that responding to your request is likely to be complex and will involve looking extensively at a high volume of data, we will be at liberty to charge you a fee. In these circumstances, once you have paid a fee then, we may require a further 2 months to respond to your request.

A subject access request (SAR) should be submitted to Sheldon Paule using the following email address: datarep@cameronkennedy.com.

Contact

If you are dissatisfied about any aspect of the way in which your data is processed or have any questions, comments and requests regarding this privacy notice you should in the first instance refer the matter to Sheldon Paule using the following email address: datarep@cameronkennedy.com. This does not affect your right to make a complaint to the Information Commissioner’s Office.

3rd May 2018                                                                                                                                             Version 3   

                                                                                                                                                      Copyright © Lawspeed Ltd 2018






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