– It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
– For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the GDPR), the company responsible for your personal data is (“Chiumento Recruitment Solutions Limited” or “us”).
What kind of personal data do we collect?
In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as :
– your name
– contact details
– education details
– employment history
– eligibility to work in the UK
– details about your current remuneration and benefits package value
– desired salary package
– Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website
– Extra information that you choose to tell us
– Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites
– IP address
– The dates, times and frequency with which you access our services
If you are a Chiumento customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as finding Candidates who are the right fit for you or your organisation. The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly.
We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
We collect a limited amount of data from our Website users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular.
How do we collect your personal data?
There are two main ways in which we collect your personal data:
1. Directly from you:
– Entering your details on the Chiumento website or via an application form, as part of the registration process;
– Applying for jobs through a job aggregator, which then redirects you to the Chiumento website;
2. From third parties:
– We may obtain information about you from searching for potential Candidates from third party sources, such as LinkedIn and other job sites;
We collect Clients personal data in three ways:
1. Personal data that we receive directly from you
We both share the same goal – to make sure that you have the best employees for your organisation. We will receive data directly from you in two ways:
– Where you contact us proactively, usually by phone or email; and/or
– Where we contact you, either by phone or email, or through our consultants’ business development activities more generally.
2. Personal data we receive from other sources
Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
– From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
– From delegate lists at relevant events; and
– From other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them).
3. Personal data we collect via our website
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.
We collect your personal data during the course of our work with you.
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser.
How do we use your personal data?
The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we may also use your personal data for things like marketing and profiling. Where appropriate, we will seek your consent to undertake some of these activities.
– Collecting your data from you and other sources, such as LinkedIn;
– Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
– Providing you with our recruitment services and to facilitate the recruitment process;
– Assessing data about you against vacancies which we think may be suitable for you;
– Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;
– Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
– Carrying out our obligations arising from any contracts entered into between us;
– Carrying out our obligations arising from any contracts entered into between Chiumento and third parties in relation to your recruitment;
– Facilitating our invoicing processes;
– Carrying out customer satisfaction surveys;
– Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and
– 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.
We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object.
We may periodically 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 and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
– enable us to develop and market other products and services;
– market our recruitment services 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;
– display promotional excerpts from your details on Chiumento website as a success story (only where we have obtained your express consent to do so); and
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 when you first register to us we ask you to opt-in and give us your consent.
If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time by e-mailing firstname.lastname@example.org or via your candidate portal.
Although at present all our recruitment activities involve human-decision making during the process, we may in the future use fully automated technologies such as expert systems or machine learning to complete a Candidates selection process from end-to-end, where appropriate and in accordance with any local laws and requirements.
Where appropriate, we will seek your consent to carry out some or all of these activities. If you do not provide consent to profiling, your application will continue to be reviewed manually for opportunities you apply for, but your profile will not be automatically considered for alternative roles. This is likely to decrease the likelihood of us successfully finding you a new job.
You have the right to withdraw that consent at any time by e-mailing email@example.com or via your candidate portal.
The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. This may involve identifying Candidates who we think will be the right fit for you or your organisation. The more information we have, the more bespoke we can make our service.
Obviously, our main area of work is recruitment, through providing you with Candidates. We’ve listed below the various ways in which we use your data in order to facilitate this.
– Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities;
– Keeping records of our conversations and meetings, so that we can provide targeted services to you;
– Undertaking customer satisfaction surveys; and
– Processing your data for the purpose of targeting appropriate marketing campaigns.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
If you are not happy about this, in certain circumstances you have the right to object.
Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.
If you are not happy about this, you have the right to opt out of receiving marketing materials from us by contacting firstname.lastname@example.org
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.
– To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
– To offer services to you or to obtain support and services from you;
– To perform certain legal obligations;
– To help us to target appropriate marketing campaigns; and
– In more unusual circumstances, to help us to establish, exercise or defend legal claims.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
If you are not happy about this, in certain circumstances you have the right to object.
We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs to you that we think you’ll be interested in. If you are also a Candidates or Clients of Chiumento Recruitment Solutions Limited, we may use data from your use of our websites to enhance other aspects of our communications with, or service to, you.
Please note that communications to and from Chiumento employees including emails may be reviewed as part of internal or external investigations or litigation.
Who do we share your personal data with?
We may share your personal data with various parties, in various ways and for various reasons; this includes transferring personal data in unencrypted CV attachments by e-mail to our clients. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we may also share your information with associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.
We will share your data primarily to ensure that we provide you with a suitable pool of Candidates. Unless you specify otherwise, we may share your information with associated third parties such as our service providers to help us meet these aims.
Unless you specify otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.
Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.
How do we safeguard your personal data?
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately by e-mailing email@example.com
How long do we keep your personal data for?
If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of two years, we will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).
How can you access, amend or take back the personal data that you have given to us?
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please e-mail firstname.lastname@example.org. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
• Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
• Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time.
• Data Subject Access Requests (DSAR): Just so it’s clear, 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. At this point we may comply with your request or, additionally do one of the following:
– we may ask you to verify your identity, or ask for more information about your request; and
– where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
• Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 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.
• Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.
• Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.
• If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example job role emails or Chiumento newsletters) by clicking the unsubscribe link in the email.
Who is responsible for processing your personal data on the Chiumento website?
Chiumento controls the processing of personal data on its website.
What are cookies and how do we use them?
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
How to reject cookies
If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings.
Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
For more information generally on cookies, including how to disable them, please refer to aboutcookies.org.
OUR LEGAL BASES FOR PROCESSING YOUR DATA
• Article 6(1)(f) of the GDPR is the one that is relevant here – it 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.”
• In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent.
• Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:
– you have to give us your consent freely, without us putting you under any type of pressure;
– you have to know what you are consenting to – so we’ll make sure we give you enough information;
– you should have control over which processing activities you consent to and which you don’t. and
– you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We will keep records of the consents that you have given in this way.
As we have mentioned, you have the right to withdraw your consent to these activities.
ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS
• Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
• This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY
Details of your local supervisory authority: The Information Commissioner’s Office.
• Phone: 0303 123 1113
• Email: email@example.com