Privacy Notice
We are a recruitment business which provides work-finding services to its clients and work-seekers. We must process personal data (including sensitive personal data) so that we can provide these services – in doing so, we act as a data controller.
You may give your personal details to us directly, such as on an application or registration form or via our website. This site is managed in accordance with the relevant data protection legislation in the UK. The data controller is Nick Collins, Director of Anthony Cole Associates . You can contact our privacy officer at ncollins@anthonycoleassociates.com. Anthony Cole Associates Ltd collects data from another source such as a jobs board. We must have a legal basis for processing your personal data. Our purpose is for providing you with work-finding services and/or information relating to roles relevant to you. We will only use your personal data in accordance with the terms of the following statement.
- Information collected: Your IP Address, Technical information about your browser, The pages you visit and your activities whilst browsing our site.
- Purpose: To help us to understand how people use our site, To help our service providers to diagnose and repair faults, To help us to detect and respond to hacking and other criminal activity.
- Legal basis: Legitimate interests.
- Your contact details: To allow us to respond to your enquiry, To provide you with the information / mailing lists that you have requested.
- Information you provide on a contact form: Consent.
Please note that this list only applies to your use of our website. If you interact with us in other ways, then additional privacy notices detailing other information and purposes will also apply.
1. Collection and use of personal data
A. Purpose of processing and legal basis
We may collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to offer these services to you are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have
- To fulfil a contractual obligation that we have with you.
B. Categories of data
We may collect the following personal data on you:
Personal data
- Name
- Date of birth (where included on CV and Photo ID)
- Contact details, including telephone number, email address and postal address
- Experience, training and qualifications
- CV
- Passport or Driving Licence (Photo ID)
Sensitive personal data (as requested and submitted to Anthony Cole Associates
- Disability/health condition relevant to the role
- Criminal conviction
C. Legitimate interest
This is where we have a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where we have relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- For us to provide you with work-finding services.
- For us to process with or transfer your personal data to our client’s in order to provide you with work-finding services. (Please note the client will be named and transfer agreed on a case by case basis).
- For us to process your data on a computerised database provided by Adapt Bond in order to provide you with work-finding services.
D. Recipient/s of data
We will process your personal data and/or sensitive personal data with the following recipients:
- Companies who are looking for your skills, after discussion regarding the role offered.
- Job Boards such as (but not limited to) REED, GAAP and Total Jobs.
2. Overseas Transfers
We will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
3. Data retention
We will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003 require us to keep work-seeker records for at least one year from
(a) the date of their creation; or
(b) after the date on which we last provide you with work-finding services.
We must also, where necessary, keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Where we have obtained your consent to process your personal and sensitive personal data, we will do so in line with our Data Retention Policy. Upon expiry of that period we will seek further consent from you. Where consent is not granted we will cease to process your personal data and sensitive personal data.
4. Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data we process on you;
- The right of access to the personal data we process on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to us processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Nick Collins, Director of Anthony Cole Associates by email: ncollins@anthonycoleassociates.com.
There may be circumstances where we will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that we processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
5. Source of the personal data
The Company sourced your personal data/sensitive personal data by the following means:
- By direct contact with you regarding a work opportunity or request for work finding support.
- on job boards such as (but not restricted to) REED, GAAP and Total Jobs and through Linkedin.
This information did not come from a publicly accessible source.
6. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact:
Nick Collins, Director of Anthony Cole Associates by email: ncollins@anthonycoleassociates.com.
Data Protection Officer: Sagari Ltd, Basepoint Business Centre, Little High Street ,Shoreham -by-Sea, West Sussex BN43 5EG
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.