Introduction
Jacob Thomas Associates Ltd is committed to being transparent about how it handles your personal information, to protecting the privacy and security of your personal information and to meeting its data protection obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018.
The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal information. We are required under the GDPR to notify you of the information contained in this privacy notice.
This Privacy Notice 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 as an emergency contact.
It is important to point out that we may amend this Privacy Policy from time to time.
Please visit this page if you want to stay up to date, as we will post any changes here.
What types of personal information do we collect about you?
Personal information is any information about an individual from which that person can be directly or indirectly identified. It doesn’t include anonymised data, i.e. where all identifying particulars have been removed. There are also “special categories” of personal information, and personal information on criminal convictions and offences, which requires a higher level of protection because it is of a more sensitive nature. The special categories of personal information comprise information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data.
Candidate Data
Depending on the relevant circumstances and applicable local laws and requirements, we
may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests.
Please note that the above list of categories of personal data we may collect is not exhaustive.
Client Data
We collect and use information about you, or individuals within your organisation, in the course of providing you services such as: (i) finding Candidates who are the right fit for you or your organisation. We collect your data Directly from you; and from third parties (e.g. our Candidates) and other limited sources (e.g. online and offline media/including credit checks where required). When 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.
Supplier Data
We collect 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 that you provide (if this is part of the contractual arrangements between us). 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.
Website Users
We collect a limited amount of data from our Website Users which we use to help manage the services we provide. This includes information that you have provided e.g name and email address, such as how you use our website, the frequency with which you access our website and the times that our website is most popular. Our Website Hosting Provider may also collect information on how users access the Website by using a tracking ID unique to each user through the use of cookies.
What are Cookies?
A cookie is a piece of data stored on the user’s computer tied to information about the user. Our Website Hosting Provider may use both session ID cookies and persistent cookies. For session ID cookies, once you close your browser or log out, the cookie terminates and is erased. A persistent cookie is a small text file stored on your computer’s hard drive for an extended period of time. Your browser’s help file contains information and instructions for removing persistent cookies. Session ID cookies may be used by our Website Hosting Provider to track user preferences while the user is visiting the website. They also help to minimise load times and save on server processing. Cookies used on by our Website Hosting Provider do not contain personally identifiable information.
We use Google Analytics on our website. How Google uses the data when you use our website may be found at https://policies.google.com/privacy/partners?hl=en-GB&gl=uk You may disable the Google Analytics function by means of a browser add-on to ensure the prevention of the sending of any analytical information to Google.
Persons whose data is received from candidates and staff.
Referees and Emergency contact details are collected only where a Candidate or a member of our staff puts you down as their emergency contact or where a Candidate gives them to us in order for you to serve as a referee.
How Do We Collect Your Personal Data?:
We collect Candidate personal data in three ways:
1. Personal data that you, the Candidate, give to us
2. Personal data that we receive from other sources
3. Personal data that we collect automatically
Personal data you give to us
Jacob Thomas Associates Ltd needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities.
There are numerous ways you can share your information with us, these include:
When a call is recorded we collect:
Personal data revealed during a telephone call will be digitally recorded for example name and contact details to deliver appropriate services.
Occasionally ‘special category’ personal information may be recorded where an individual voluntarily discloses health, religious, ethnicity or criminal information to support their request for advice and/or services.
The recordings will be stored on a secure server hosted by our phone provider (currently Digital Communications) which will only be accessible by senior members of the management team, who will be issued with a username and password.
Call recordings will be used:
Sharing personal data
We may share a call recording with an Investigating Officer in order for them to respond to a complaint or issue.
Sharing data under Data Protection legislation
We may be required or permitted, under Data Protection legislation, to disclose a call recording including your personal data without your explicit consent, for example if we have a legal obligation to do so, such as for:
What is the legal basis that permits us to use your information?
Under data protection legislation we are only permitted to use your personal data if we have a legal basis for doing so as set out in the data protection legislation. We will process your personal data for the purposes of providing you with work-finding services. The legal bases we rely upon to offer these services to you include at least one of the following:
Retaining personal data
Recordings are kept securely and confidentially. They will be held for no more than 90 days, unless required to be retained for an investigation, legal reasons or a potential safeguarding concern.
Personal data we collect automatically
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.
Client Data
We collect Client personal data in three ways:
It is always our aim to make sure that you have the best staff for your organisation.
We will receive data directly from you in two ways:
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
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).
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.
Website Users:
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.
Why and How do we use your personal data?
We will only use your personal information when the law allows us to. These are known as the legal bases for processing. We will use your personal information in one or more of the following circumstances:
We may also occasionally use your personal information where we need to protect your vital interests (or someone else’s vital interests).
We need all the types of personal information listed under “What types of personal information do we collect about you?” primarily to enable us to take steps at your request to enter into a contract with you, or to enter into a contract with you, and to enable us to comply with our legal obligations. In some cases, we may also use your personal information where it is necessary to pursue our legitimate interests (or those of a third party), provided that your interests or your fundamental rights and freedoms do not override our interests. Our legitimate interests include: pursuing our business by employing employees, workers and contractors; managing the recruitment process; conducting due diligence on prospective staff and performing effective internal administration.
Candidate Data
The purposes for which we are processing, or will process, your personal information are to:
Please note that we may process your personal information without your consent, in compliance with these rules, where this is required or permitted by law.
What if you fail to provide personal information?
If you fail to provide certain personal information when requested or required, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. You may also be unable to exercise your statutory or contractual rights.
Client Data
We use your data to enable candidates to find suitable job roles within your organisations.
To maintain the effective running of the business through contractual agreements and to comply with legal obligations.
Supplier Data
To maintain the effective running of the business through contractual agreements and to comply with legal obligations.
Persons whose data we receive from candidates and staff
Referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them. We use
the personal details of a Candidates or Staff member’s emergency contacts in the case of
an accident or emergency affecting that Candidates or member of Staff.
Website Users
We use your data to help us to improve our service, 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 Candidate or Client of Jacob Thomas Associates, we may use data from your use of our websites to enhance other aspects of our communications with, or service to, you.
Who do we share your personal data with?
Candidate Data
Your personal information may be shared internally within the Company for the purposes of the recruitment exercise, including with members of the HR department, members of the recruitment team, managers in the department which has the vacancy and IT staff if access to your personal information is necessary for the performance of their roles.
The Company will not share your personal information with third parties during the recruitment process unless your job application is successful and we make you an offer of employment or engagement. At that stage, we may also share your personal information with third parties (and their designated agents), including: External organisations for the purposes of conducting pre-employment reference and employment background check these may include:
We may also need to share your personal information with a regulator or to otherwise comply with the law.
We may share your personal information with third parties where it is necessary to take steps at your request to enter into a contract with you, or to enter into a contract with you, where we need to comply with a legal obligation, or where it is necessary for our legitimate interests (or those of a third party).
Client Data:
We will share your data with a suitable pool of Candidates. we will share your data with our chosen bank for financial purposes.
Supplier Data:
Unless you specify otherwise, we may share your information with any of associated third parties such as our service providers and organisations to whom we provide services.
Persons whose data is received from candidates and staff.
Unless you specify otherwise, we may share your information with any of our group companies and
associated third parties such as our service providers and organisations to whom we provide services.
Website Users:
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?
Jacob Thomas Associates Ltd has put in place measures to protect the security of your personal information. It has internal policies, procedures and controls in place to try and prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities. You can obtain further information about these measures from our Compliance Team who can be contacted via email by clicking here
Where your personal information is shared with third parties, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes.
Jacob Thomas Associates Ltd also has in place procedures to deal with a suspected data security breach and we will notify the Information Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.
How long do we keep your personal data for?
Jacob Thomas Associates will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed.
If your application for employment or engagement is unsuccessful, Jacob Thomas Associates Ltd will generally hold your personal information for one year after the end of the relevant recruitment exercise but this is subject to: (a) any minimum statutory or other legal, tax, health and safety, reporting or accounting requirements for particular data or records, and (b) the retention of some types of personal information for up to six years to protect against legal risk, e.g. if they could be relevant to a possible legal claim in a tribunal, County Court or High Court. If you have instructed Jacob Thomas Associates Ltd to keep your personal information on file in case there are future suitable employment opportunities with us, the Company will hold your personal information for a further year after the end of the relevant recruitment exercise, or until you withdraw your instructions if earlier.
If your application for employment or engagement is successful, personal information gathered during the recruitment process will be retained for the duration of your employment or engagement and in accordance with the privacy notice for employees, workers and contractors.
Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable.
In some circumstances we may anonymise your personal information so that it no longer permits your identification. In this case, we may retain such information for a longer period.
Your rights in connection with your personal information
As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:
If you wish to exercise any of these rights, please contact the office in writing or email your request by clicking here. We may need to request specific information from you in order to verify your identity and check your right to access the personal information or to exercise any of your other rights. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact the office in writing or click here to email your request. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.
If you believe that Jacob Thomas Associates Ltd has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office (ICO) at any time. The ICO is the UK supervisory authority for data protection issues.
Why and how do we use your sensitive personal information?
We will only collect and use your sensitive personal information, which includes special categories of personal information and information about criminal convictions and offences, when the law allows us to.
Some special categories of personal information, i.e. information about your health, and information about criminal convictions and offences, is processed so that we can perform or exercise our obligations or rights under employment law and in line with our data protection policy.
We may also process information about your health and information about any criminal convictions and offences where we have your explicit written consent. In this case, we will first provide you with full details of the personal information we would like and the reason we need it, so that you can properly consider whether you wish to consent or not. It is entirely your choice whether to consent. Your consent can be withdrawn at any time.
The purposes for which we are processing, or will process, health information and information about any criminal convictions and offences, are to:
Where the Company processes other special categories of personal information, i.e. information about your racial or ethnic origin, religious or philosophical beliefs and sexual orientation, this is done only for the purpose of equal opportunities monitoring in recruitment and in line with our data protection policy. Personal information that the Company uses for these purposes is either anonymised or is collected with your explicit written consent, which can be withdrawn at any time. It is entirely your choice whether to provide such personal information.
We may also occasionally use your special categories of personal information, and information about any criminal convictions and offences, where it is needed for the establishment, exercise or defence of legal claims.
What if you fail to provide personal information?
If you fail to provide certain personal information when requested, we may not be able to process your job application properly or at all, we may not be able to enter into a contract with you, or we may be prevented from complying with our legal obligations. You may also be unable to exercise your statutory rights.
Transferring personal information outside the European Economic Area
Jacob Thomas Associates Ltd will not transfer your personal information to countries outside the European Economic Area
Change Of Purpose
We will only use your personal information for the purposes for which we collected it, i.e. for the recruitment exercise for which you have applied. if your job application is unsuccessful, the Company may wish to keep your personal information on file for in case there are future suitable employment opportunities with us.
We do not envisage any change of purpose, however, we will ask for your consent before we keep your personal information on file for this purpose. Your consent can be withdrawn at any time.
Automated Decision Making
We do not envisage that any recruitment decisions will be taken about you based solely on automated decision-making, including profiling.
Marketing Activities
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:
We need your consent for some aspects of these activities which are not covered by our
legitimate interests (in particular, the delivery of direct marketing to you through digital
channels) and depending on the situation, we’ll ask for this via a soft-opt-in. Please note that we will comply with any additional local law requirements.
Changes to this privacy notice
The Company reserves the right to update or amend this privacy notice at any time.
Please visit this page if you want to stay up to date, as we will post any changes here.
Contact
If you have any questions about this privacy notice or how we handle your personal information, please write to The Company Secretary, Jacob Thomas Associates Ltd. Unit 5 Westleigh Business Park. Blaby. Leicester. LE8 4EZ or email us by clicking here.