This policy outlines how KCL process any personal data we collect from you or that you provide to us or which we may obtain from other sources (such as job boards) because you provided the personal data to them with the intention of it being collected by 3rd parties such as KCL. KCL is committed to protecting and respecting the privacy of its clients, candidates, employees and any other users of our services.
Purposes for which Personal data is collected, processed, used or disclosed by KCL
KCL may receive and collect your personal data including but not limited to your name, contact details, date of birth, qualifications, experience, previous employment or any other information from your CV, details of your referees, citizenship and immigration status (i.e. information required to determine your eligibility to work in the UK or in other countries where relevant) and information from supporting documents provided by yourself (i.e. scan of your passport or driving license), emergency contacts, details of dependents, next of kin, financial information, and any other relevant information. On occasions, this may also include special categories of personal data, medical information and information regarding your criminal record or security clearance for certain roles. We may collect this information from you (i.e. from your CV, by phone, email or otherwise), your referees (which you provided consent for us to contact), educational organisations, professional bodies, the Disclosure and Barring Service (DBS), the Home Office, credit reference agencies or other third party with which we work, such as job boards, employment businesses or agencies, umbrella companies, etc.
This information is held, processed, used and disclosed by us as follows:
- to provide our services to you and your services to our clients
- to assess your suitability for assignments/vacancies which we consider may be suitable for you and of interest to you
- to enable you to submit your application and CV for specific assignments/vacancies and/or for inclusion in our CV database for future consideration; for us to assess your suitability and eligibility for current or future assignments/vacancies; for us to apply on your behalf (with your consent) and to progress existing applications with our clients
- to answer your questions and queries
- to carry out a fair recruitment process in compliance with all applicable legislation
- to make the best possible decision to shortlist for each stage in the recruitment process and ultimately, if relevant, recruit
- to carry out our obligations arising from any contracts entered into between you and KCL or KCL and its clients (where you provide your services to our clients)
- to take steps necessary at your request prior to entering into a contract
- To maintain records and to comply with legal and regulatory obligations and general good business practice
- For reasons of substantial public interest
- to maintain our business relationship where you are a user of our website, a client or candidate
- to fulfill contractual obligations with our clients and other relevant 3rd parties
- to maintain, expand and develop our business
- to third parties where they were asked to provide services that we, you or our client have requested including checking services for references, qualifications and criminal history (as required), verification of the details you have provided from third party source, psychometric evaluation and/or skill test
- to process data where we are legally obliged to process such data or where the processing is necessary for the purposes of carrying out our obligations or exercising our legal rights
- We may also release personal information to third parties if we have reason to believe in good faith that we are required by law to do so
- to third parties who provide services to us, such as professional advisors, payment services, IT providers working on our computing systems, research and mailing houses. These third parties comply with similar undertakings of privacy and confidentiality as KCL
- to use your information on an anonymised basis to monitor compliance with our equal opportunities policy
- respond to and defend against legal claims
- to notify you about changes to our service
Legal basis for processing personal data:
The legal basis for the processing of personal data is as follows:
- for the performance of a contract to which you are party to or in order to take steps to enter into a contract
- for compliance with legal obligations to which we are subject or may become subject, such as: crime prevention, the collection of taxes or duties, compliancewith any applicable law
- for the purposes of our legitimate interests or those of a third party, as outlined above in this policy
- Where you give your consent to the processing of your personal data for one or more specific purposes, for example, applying for a vacancy or assignment or participation in marketing activities. 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
- for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
Where we provide you with work finding services, the provision of personal data is a statutory requirement and a requirement necessary to enter into a contract with us. The provision of certain category of personal data may be required by our clients. You will be expected under these circumstances to provide us with such personal data, should you wish to benefit from our services.
We may not be able to enter into a contract with you if the information is not provided to us. Where you have entered into a contract with us and you refuse to provide any information required under the contract or by law, we reserve the right to terminate our business relationship with you. Where applicable, we may refer your refusal to the relevant statutory authority requesting such information.
Where your information is held
How long we keep your data
We will only hold your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of complying with applicable legal or reporting requirements, our contractual obligations or our legitimate interests as a controller.
Some categories of personal data we hold will need to be retained for longer than others. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purpose for which they are processed, the applicable legal requirements and our contractual obligations. Other personal data will be held for no longer than is necessary to protect our legitimate interest as a controller.
In some circumstances we may anonymise personal data so that it can no longer be associated to you, in which case we may use such information without further notice to you.
Subject to the above, we will hold your CV and information about previous assignments/vacancies to which you applied for as long as we provide relevant services and until such time that you request to have your CV removed from our database.
We take information security in general and the security of your data in particular seriously. We have internal processes and controls to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. We will update these measures as new technology becomes available, as appropriate.
We may periodically contact you by telephone, email or other digital means for marketing purposes relating to our services, our website, and/or to research your views on our services. We will require your consent if we intend to use your data for such purposes. You have the right to withdraw your consent if you do not want to be contacted for such purposes.
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 related services, we will take your consent as given unless you have withdrawn it. This is referred to as soft opt-in consent and is beneficial as it allows us to suggest other assignments, vacancies or services to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. In all other types of e-marketing, we are required to obtain your explicit consent.
Opt-Out – you are entitled to opt-out from receipt of marketing communication at any time and free of charge by sending an email to email@example.com .
Website Cookies – where cookies are used on our website, a message will appear to ensure you are aware of this and approve of cookies being used.
We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to:
- Request a copy of the personal data that we hold
- Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data
- Request that we restrict processing of your data in certain circumstances
- Request that data is erased where the continued use of that data cannot be justified
- Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process
- Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations
- Request that inaccurate or incomplete data is rectified
- Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract
- Make a complaint to the Information Commissioner’s Office Request that direct marketing by us to you is stopped
- We reserve the right to refuse requests or charge a reasonable fee if your request is frivolous, unfounded, repetitive or excessive
- We reserve the right to remove your data from our systems at any time and for any reason only keeping data required for legal and contractual compliance and to prove compliance
Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third party source.
Automated decision making
KCL do not use automated decision making in any of its business activities. As a small consultancy providing a personalised service, we pride ourselves in our ‘human touch’.
Any changes to this policy will be posted in this page so you are always aware of what information KCL collect, how it is used and under what circumstances if any it is disclosed. Where appropriate, we may notify you by email of any future changes.
For any other information, questions or concerns about this policy, please contact us at: firstname.lastname@example.org