JasperRose Limited is committed to protecting and respecting your privacy and security of your personal information.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation that replaces the Data Protection Regulation (Directive 95/46/EC). The GDPR aims to harmonise data protection legislation across the European Union, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
- Clients: our customers, clients and prospective customers and clients to whom we provide or market our recruitment services in the course of our business.
- Additional Contacts: these may include Candidates’ and JaperRose Employees emergency contacts and referees. We will only contact them in appropriate circumstances.
- Website Users: any individual who accesses our website
- Employees: includes employees and interns engaged directly in the business of JasperRose (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to JasperRose (even though they are not classed as employees).
For the data protection legislation from time to time, in force, JasperRose Limited is the data controller and is responsible for your personal data.
Our nominated Data Protection Representative (DPR) is Rosie O’Callaghan and the DPR’s contact details can be found at [email protected].
You must read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.
What kind of personal data do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been anonymised.
In order to provide you with the best possible service in supporting you with your career and in finding a new role, we need to process certain information about you. Depending on the relevant circumstances, we may collect some or all of the information listed below to enable us to offer you employment opportunities that are tailored to your circumstances and your interests. Please note that the below list of categories of personal data we may collect is not exhaustive.
- Contact details;
- Education details;
- Employment history;
- Date of birth;
- Marital status;
- Emergency contacts and details of any dependents;
- Referee details;
- Immigration status (whether you need a work permit);
- National Insurance number
- Nationality/citizenship/place of birth;
- A copy of your driving license and/or passport/identity card;
- Financial information (where we need to carry out financial background checks);
- Social security number (or equivalent in your country) and any other tax-related information;
- Extra information that you choose to provide to us;
- Extra information that your referees choose to provide to us about you; Extra information that our Clients may provide to us about you, or that we find from other third-party sources such as job sites;
- Details about your current remuneration, pensions and benefits arrangements;
- 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;
- Employment records (including job titles, work history, working hours, training records and professional memberships);
- References and other information included on a CV or Cover Letter;
- IP address;
- The dates, times and frequency with which you access our services; and
- CCTV footage if you attend our premises.
Where appropriate or necessary (and in accordance with legal requirements), we may also collect information related to your health or details of any criminal convictions (where this is required for a role that you are applying for). We may ask you to provide diversity information (voluntarily, including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information) for the reasons and in the circumstances set out below. To the extent that you access our website, we will also collect certain data from you.
We need to collect and use information about JasperRose clients, or individuals at your organisation, to be able to provide you with recruitment services (e.g. finding the right Candidate for your business) or notifying you of content published by JasperRose which is likely to be relevant and useful to you. The data we collect about Clients is overall 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 also hold information relating to your online engagement with material published by JasperRose, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us.
We need some information from our Suppliers to ensure that our relationship and services provide and operate efficiently. Information we collect includes contact details (such as email addresses, names and telephone numbers) of relevant contacts 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 provided (if this is part of the contractual arrangements between us).
This could include referees or emergency contacts. We need this information in order for us to be able to support Candidates to find a relevant career opportunity safely and securely; to provide for every eventuality for them and our Employees, we need some basic background information. We will obtain basic contact details (such as name, email address and telephone number) so that we can contact you either for a reference or because it has been communicated with us that you are an emergency contact for one of our Candidates or current/prospective Employees.
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 the frequency with which you access our website, how you use our website, the browser type, the location you view our website from the language you choose to view it in, and the times that our website is most popular.
How do we collect your personal data?
There are three main ways in which we collect your personal data:
- Personal data that you provide to us:
JasperRose collects personal information from you to enable us to provide you with the best service possible and so we contact you about relevant job opportunities and additional services that we offer. The ways you share your data with us may include:
- Entering your details on the JasperRose website or via an application form/through registration;
- Leaving a hard copy CV at a JasperRose event, external events or at our office;
- Emailing your CV to a JasperRose consultant or meeting with them;
- Applying for jobs through a job aggregator, which then redirects you to the JasperRose website;
- Entering your personal details into a JasperRose microsite; or
- Entering a competition e.g. on a social media channel
- Personal data that we receive from additional sources e.g. third parties:
This may include personal data received in the below circumstances:
- Your referees may disclose personal information about you;
- We may obtain information about you from searching for potential Candidate from third party sources, such as job boards and also LinkedIn;
- JasperRose Clients may share or disclose personal information about you with JasperRose;
- If you connect with us on social media e.g. by pressing ‘like’ on our Facebook page or by ‘following us or liking content on Twitter or Instagram we will receive your personal information from these channels.
- Personal data collected automatically:
When accessing our website or reading/viewing 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. For more information, see the “How do we use your personal data” section below.
We collect Client personal data in the following 3 ways:
- Personal data that we receive directly from you:
- 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.
- Personal data that 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 (either JasperRose directly or through engaging other organisations to support us to do so);
- From delegate lists at relevant events; and
- From other limited sources and third parties (for example from our Candidates e.g. providing us with contact information for referee purposes)
Personal data we collect via our website:
Through access our website or reading/viewing 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 when we work with you, this information will usually be provided to us directly by you.
- This is collected when candidates or employees/prospective employees provide us with your contact details as they have stated you as their emergency contact or referee.
- When you visit our website, there is certain information that we may automatically collect whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website.
- We collect your Data automatically via cookies, in line with cookie settings in your browser. If you are also a Candidate or Client of JasperRose, we may use data from your use of our websites to enhance other aspects of our communications with our service to you.
How do we use your personal data?
We mainly use your personal details for recruitment activities as stated below as well as marketing activities and on occasion for diversity monitoring. Where necessary, we will ask for your consent to complete some of these. See further information below on these activities:
- Recruitment Activities: We use and process your personal data, to support you in finding the right career opportunity with the right business. Information for recruitment activities is used in the following way:
Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
- Collecting your data from you and other sources, such as LinkedIn;
- Providing you with our recruitment services and facilitating 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 JasperRose and third parties in relation to your recruitment;
- Facilitating our payroll and invoicing processes;
- Carrying out customer satisfaction surveys;
- Verifying details you have provided, using third party resources (such as psychometric evaluations or skills tests), or requesting information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
- 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 see it necessary to do so for our legitimate interests (see further information below). If you are dissatisfied with this, you may have the right to object, please email our Data Protection Representative, Rosie O’Callaghan, at [email protected] for further information.
- Marketing Activities:
From time to time we may send you the marketing information that we feel may be of interest to you, or to ask for assistance with roles we are recruiting e.g. asking for referrals. We may use your data for the reasons listed below (this is not exhaustive):
- enable us to develop and market other products and services;
- market our recruitment services (including permanent, temporary, fixed-term contract, CV service and outplacement services) to you;
- send you information or details of relevant market insight, promotions, offers, networking and additional events, and further relevant information which we think might be of interest to you;
- host promotional content from your details on JasperRose’s website(s) e.g. a testimonial (only where we have obtained your express consent to do so);
- provide you with information about certain discounts and offers that you may be eligible for as a result of your relationship with JasperRose
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 consent is a specific type of consent that applies where you have previously engaged with us (for example by submitting a job application or CV or registering a vacancy to be filled), and we are marketing other recruitment-related services. 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 you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent. If you are not happy about our marketing approach, you have the right to withdraw your consent at any time by emailing our Data Protection Representative, Rosie O’Callaghan, at [email protected]. Please be aware that even if you have opted out from our marketing communications, it may be the case that your details are recaptured through public sources in an unconnected marketing campaign. We will do our best to ensure this does not happen; however, if it does, please opt-out again.
- Equal opportunities monitoring and other sensitive personal data
- Some of the data we may (in appropriate circumstances and accordance with local law and requirements) collect about you is for diversity monitoring. This is usually to be able to submit your CV and application to a role we are working on with our Client who requires this information in accordance with their equal opportunities monitoring. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. We may therefore disclose this (suitably anonymised where relevant) data to Clients where this is contractually required or it is requested by the Client for their own compliance purpose.
- As this information is more sensitive, stricter data protection rules apply to it and we will obtain your explicit consent before we can use it and will ask you to explicitly and clearly consent that you agree to us collecting and using this information (usually via email or a form)
- We may collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your explicit consent.
- If you are dissatisfied with this, you have the right to withdraw your consent at any time by emailing our Data Protection Representative, Rosie O’Callaghan, at [email protected]
- To help us to establish, exercise or defend legal claims. In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
The main ways in which we use your data is for recruitment, marketing and legal claims. We use your data to ensure that the contractual arrangements between us can be efficiently run and adhered to and to ensure we maintain a strong working relationship. The more information we have about you/from you, the more we can tailor our service. The 3 main ways in which we use your data is as follows:
- Recruitment Activities:
- We store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements on our database.
- From time to time we may undertake customer satisfaction surveys; 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.
- To provide professional references on any previously employed candidate
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 (see further information below). Or please contact our Data Protection Representative, Rosie O’Callaghan, at [email protected]
- Marketing Activities
- 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 dissatisfied with this, you have the right to opt-out of receiving marketing materials from us by emailing our Data Protection Representative, Rosie O’Callaghan at [email protected]
- To help us to establish, exercise or defend legal claims:
- In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
We only use your information to:
- 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 (see further information below). 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 (see further information below). Or please contact our Data Protection Representative, Rosie O’Callaghan, at [email protected].
We will only use the information that our Candidate or prospective employees gives us about you for the following purposes:
- If our Candidates or employees states your contact details as they are providing you as an emergency contact, we’ll contact you in the case of an accident or emergency affecting them; or
- If you were stated by our Candidate or a prospective employee as a referee, we will contact you in order to obtain this reference. This is part of our Candidate compliance process and may support them in securing a new role.
- If you were put down by our Candidate or a prospective employee as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests (see further information below). If you are dissatisfied by this, you have the right to object (see further information below) and can do so by contacting our Data Protection Representative, Rosie O’Callaghan, at [email protected].
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 or Candidates to you that we think you’ll be interested in. If you would like to find out more about cookies, including how we use them and what choices are available to you see further information below.
Who do we share your personal data with?
We may share your personal information within our organisation both in the EEA and outside of the EEA and with selected third parties including:
We mainly share your information with prospective employers to increase your chances of securing a new role. We may also share your information with and 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 mainly to introduce candidates to you and ensure you provide you with a relevant shortlist of Candidates. We may share your information with associated third parties such as our service providers to help us meet these aims.
We may share your information with associated third parties such as our service providers and organisations to whom we provide services.
We may share your information associated with third parties such as our service providers and organisations to whom we provide services.
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.
- For Candidates, Clients, Suppliers, Additional Contacts and Website Providers we may share data with the following:
- Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
- Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
- Third-party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
- Third-party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
- Marketing technology platforms and suppliers;
- In the case of Candidates: potential employers and other recruitment agencies/organisations to increase your chances of finding employment;
- Cloud-based storage providers;
- In the case of Candidates: third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job;
- In the case of Candidates and Additional Contacts (e.g. referees): third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws;
Where a third party processes your personal data – 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.
We require all third parties to respect the security of personal data and to treat it in accordance with the law. We do not allow third-party service providers with whom we may work to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
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 contacting our Data Protection Representative, Rosie O’Callaghan at [email protected]
Retention of your data:
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 where you are happy for us to do so. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data as well as the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data into our database unless requested to do so. For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us at [email protected].
Your Legal Rights
One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data including the right to access, correct, erase or restrict the personal data that you have given to us.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Under certain circumstances, by law, you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information.
- Request correction of the personal information that we hold about you. You also have the right to request that we correct any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the correction unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
- Request erasure of your personal information. You have the right to request that we erase your personal data in certain circumstances.
- Normally, the information must meet one of the following criteria:
- the data are no longer necessary for the purpose for which we originally collected and/or
- processed them;
- where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
- it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
- if we process the data because we believe it necessary to do so for our legitimate interests, you
- object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing
- We would only be entitled to refuse to comply with your request for one of the following reasons:
- to exercise the right of freedom of expression and information;
- to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
for public health reasons in the public interest;
for archival, research or statistical purposes; or
to exercise or defend a legal claim
- When complying with a valid request for the erasure of data we will take all reasonably practicable steps to Delete the relevant data
- Normally, the information must meet one of the following criteria:
- Object to processing this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
- The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Candidates, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless: – we can show that we have compelling legitimate grounds for the processing which overrides your interests; or – we are processing your data for the establishment, exercise or defence of a legal claim.
- If your objection relates to direct marketing, we must act on your objection by ceasing this activity. To stop receiving marketing or to change your marketing preferences please contact our Data Processing Representative, Rosie O’Callaghan at [email protected]
- Request the restriction of processing your personal information. You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest. The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
- where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
- where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
- where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
- where we have no further need to process your personal data but you require the data to establish, exercise or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
- Request the transfer of your personal information to another party. If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your JasperRose account details to another party. This right of data portability applies to (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
- Right to complain: You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we encourage you to contact us in the first instance.
Please note, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
To get in touch about the rights of access, correction, erasure or restriction please get in touch with our Data Protection Representative [email protected]. We will seek to deal with your request without undue delay, and in any event within one month, occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
How do we store and transfer your data internationally?
- Your data may be transferred:
- to third parties (such as advisers or other Suppliers to the JasperRose business);
- to overseas Clients;
- to Clients within your country who may, in turn, transfer your data internationally;
- to a cloud-based storage provider; and
- to other third parties (see the section on “Who do we share your personal data with” for more information
- We want to make sure that your data are stored and transferred in a way that is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
- by way of the data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
- by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
- transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
- where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or
- where you have consented to the data transfer.
- To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
Automated Decision Making or Profiling:
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
What’s a cookie?
- A “cookie” is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
- Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
- to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
- to help us advertise jobs to you that we think you’ll be interested in. The intention of this is to ensure you are only hearing about the most relevant opportunities for what you are looking for.
Cookies are either:
- Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
- Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website created when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).
- Cookies can also be categorised as follows:
- Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
- Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
- Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
- Personalisation cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs that are similar to jobs that you have previously browsed.
Our Legitimate Interests
Our legitimate interests in collecting and retaining your personal data are described below:
- Article 6(1)(f) of the GDPR states 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.”
- The legitimate interests in collecting and retaining your personal data should help us to provide you with a more efficient and tailored service. As per the information above you have the right to object to us processing your personal data on this basis (see section above, “Your Legal Rights”)
- We believe it’s reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site (e.g. LinkedIn), you are happy for us to collect and use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills in relation to the vacancies we are working on. If you are close to securing a role through JasperRose, your prospective employer may also want to verify any information you’ve given us (such as the results from psychometric/skills tests) or they may want us to confirm your references, qualifications and criminal records. As a recruitment agency, we introduce Candidates to Clients for employment opportunities. The exchange of personal data of our Candidates and our Client contacts is a fundamental, essential part of this process. We need to do these things so that we can function as a profit-making business, and to help you secure a new role.
- We want to provide you with relevant market insight to read and specific roles which are relevant to your next move. We, therefore, think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.
- We need to use your data for our internal administrative activities, like payroll and invoicing where relevant to ensure our service is smooth and we can provide the relevant service to you and other Candidates.
- 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.
- To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction or feedback survey. We deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.
- 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.
- We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
- If you have been put down by a Candidate or a prospective Employee as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our compliance procedure, we see this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people as a business.
- If a Candidate or Employee member has stated your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. This is vital to ensure our Candidates and Employees have a next of kin to contact in an emergency, and so is necessary for our legitimate interests.
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. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time (as set out above under Your legal rights). Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
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.
Further Contact Details:
Our nominated Data Protection Representative (DPR) is Rosie O’Callaghan and the DPR’s contact details can be found at [email protected]
201 Borough High Street
Registered number: 09728935