1.   INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our service as a recruitment specialist matching candidate to employment positions. There is a separate section for Candidate, Clients (Employers) and Users of this Website.

Personal data means any information capable of identifying an individual. It does not include anonymized data.

Flagship Consulting Construction Recruitment Specialists Ltd (Flagship Consulting) is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, please contact Tom Evans, our Data Protection Officer by email at gdpr@flagship-consulting.com or by post to:

The Data Protection Officer

Flagship Consulting Construction Recruitment Specialists Ltd

Tower House

Fairfax Street

BRISTOL

BS1 3BN

If your personal information changes please let us know so we can keep our records UpToDate and accurate. by emailing us at updatemydata@flagship-consulting.com

2.  CANDIDATE DATA.

WHERE DO WE GET YOUR DATA?

We may receive this information about you indirectly. When you are looking for a new job or want to be made aware of potentially suitable opportunities you may place personal information about yourself on job boards or show yourself as looking for a job through networking sites such as (say) LinkedIn or from other publicly available sources such as those reached through internet search engines.

Alternatively, you may provide this information to us directly via this website or by sending us your profile or by any other means.

WHAT DATA DO WE COLLECT ABOUT YOU?

Whether received directly or indirectly, this information may include your name, address, email address, telephone numbers and current and past employment history, relevant medical information or disability information – as you provide it to us directly or indirectly.

WHAT DO WE DO WITH YOUR DATA?

Match you to a job.

We use your data to match your job experiences, qualifications and aspirations with clients who are looking to recruit suitable candidates. We do some automated searching and matching, but we always use our specialist skills and knowledge to manually check any potential automated match to ensure you and our clients get the highest probability of a successful employment match.

Communicate with you effectively

In relation to matching you to a suitable vacancy we will communicate with you and you with us by various means including email, post, telephone and text. We retain copies of this communication and take notes during conversations so that we can handle the selection and placement process in an orderly way, take account of your preferences, respond to you intelligently and so we can remember the things that have been communicated in the past which may impact the present and the future.

Share your information with potential employers (our clients)

If in our professional opinion there is a good match between your profile and preferences and the requirements of a client, we will share information about you with potential employers (our clients) and communicate with them. When we share information about you with a potential employer we share your name only and no other contact information. In some cases, you may be personally identifiable from just your name and other non-contact profile details or because you are known relationally in what a specialist industry is.

To protect you, we contractually require prospective employers (our clients) to refrain from seeking to identify you or from contacting you and not to share your information with a third party and to destroy your information if you are not successful in your application. We do this via a processor agreement with each client.

Take up references about you

When you provide contact details of individuals who can provide references about you we may take these up at the request of potential clients, with your knowledge and permission.

Helping you to progress in your career and to be aware of other opportunities

We retain your data for up to 5 years. We do so because in our experience individuals want to be made aware of opportunities for career progression or to change to a similar role which may have better benefits or prospects. We will email you at least once every two years to draw your attention to the fact we still hold your details and give you an opportunity to update them or have your details removed from our database. We will not share your details with prospective employer without your knowledge.

Sensitive Personal Data.You may provide information on your profile or CV or another document information that relates to your age, gender, race, religion or sexual orientation or disability or medical condition or other sensitive personal data. Sometimes you may have provided information so that a prospective employer can consider your working capacity. Where you have made sensitive personal data about you available publicly (say) through a job board this information may be processed by us on the basis that you made it public in relation to your desire to find a job. We may pass it on to matched prospective employers (our clients) in good faith.

We will not ask you for any sensitive personal data and do not need it unless you believe that a medical condition or disability may affect your capacity to work. Where you provide this information directly to us voluntarily as part of your profile we will pass it on to a prospective employer (our client) in good faith in the knowledge that you wanted to include it knowing that it would be used to introduce you to prospective employers (our clients).

Marketing our services to you

If you have not shown yourself to be interested in being matched to suitable employers based on (say) your private LinkedIn profile status (available to us as a recruitment agency) or through sending us your profile or through posting your profile on (say) job boards, we will not contact you for marketing purposes by email, text or telephone without your prior consent. This means that if we do contact you it will be because you have responded to an advertisement or promotion and given your consent at the point of registration or submission of your details for us to contact you. Your consent was freely given, and you can withdraw your consent at any time.

To pursue or defend a legal claim.

We may process your data for the establishment, pursuance or defence of legal claims. For example, if an employer were to claim that we had fraudulently altered profile information.

WHAT IS OUR LAWFUL BASIS FOR PROCESSING?

Unless otherwise stated, we rely on our Legitimate Interest to run a lawful, legal, efficient and effective business to process your data to find you a job with an employer (our client) which will be attractive to you and to them.  Of course, you have the right to have your personal information removed from our systems at any time – except where we have a valid legal reason for retaining them.  Simply contact us using the contact details at the top of this Privacy Notice.

AUTOMATED PROCESSING AND OTHER USE OF YOUR DATA

When seeking to match your profile with a job you want and while ensuring your profile matches the requirements of an employer (our client) we may use automated processing including key word logic to find a match. However, this is only one part of a process used in some cases to initially narrow the field of matching candidates. None of this automated processing leads to automated decision making.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at gdpr@flagship-consulting.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

3. EMPLOYER DATA

Employer data means Personal Data About Our Clients and Prospective Clients

WHERE DO WE GET YOUR DATA?

You may provide your contact details to us directly, or we may obtain these from other sources such as online or offline directories or networks such as LinkedIn. We may obtain your details via recommendation or business networking events or by desk research to find organisations and people likely to need or benefit from our specialist services. We may obtain and use your details because you have published a vacancy – provided you have not stated that you do not wish to be contacted by an agency.

WHAT DATA DO WE COLLECT ABOUT YOU

When you are looking for a candidate that matches a job vacancy or opportunity within your organisation we will record details about your company and about you or others within your organisation. These details may include your business address, email address, mobile phone number and notes about you and your requirements and those of your organisation which help us to successfully match potential candidates.

WHAT DO WE DO WITH YOUR DATA

Communicate with you effectively.

We may communicate with you as part of a new, developing or ongoing business relationship where we seek to understand your human resource needs and find candidates which match the needs of your organisation. We will communicate with you based on our Legitimate Interest by various means including email, post, telephone and text. We retain copies of this communication and take notes during conversations so that we can handle the selection and placement process in an orderly way, take account of your preferences, respond to you intelligently and so we can remember the things that have been communicated in the past which may impact the present and the future.

Market to you.

We may use your data to contact you to introduce our services to you. We do this because we believe that the profile of your organisation makes it likely that you will have opportunities which match the aspirations of candidates we are working with.  We may use your data to contact you as an existing or past client to make you aware of the latest information about our organisation and the services we offer along with our views as a specialist about the employment landscape in the industries we serve and in which you operate.

Introducing Candidates to you.

We may use your data to introduce specific candidates which in our professional opinion may be of interest to you in the development of your organisation and the fulfilment of your human resourcing needs.

Carry Out Financial Transactions.

When we do business with you we will use your data to invoice you for our services. We do this on the basis that processing is necessary for the fulfilment of a contract between our organisations.

WHAT IS OUR LAWFUL BASIS FOR PROCESSING CLIENT DATA?

Unless otherwise stated, we rely on our Legitimate Interest to run a lawful, legal, efficient and effective business to process your data to find candidates likely to be attractive to you.  Of course, you have the right to have your personal information removed from our systems at any time – except where we have a valid legal reason for retaining them.  Simply contact us using the contact details at the top of this Privacy Notice.

4. YOU AS A VISITOR TO OUR WEBSITE

WHERE DO WE GET YOUR DATA AND WHAT DO WE DO WITH YOUR DATA?

User Data.

We track your use of our website using cookies. A cookie sits on the device that you used to browse our website and, in some cases, will be replicated across other devices you use. We do this so that we can understand how visitors arrived at our site, what they do when on the site and when they leave the site. This helps us to improve the site making it easier for visitors to navigate and to create content that makes the site more relevant.

Technical Data.

During this process we track data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

We may use User Data and Technical Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use this data to send other marketing communications to you in ways which are compliant with GDPR. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

We may collect data about you when you provide the data directly to us (for example by filling in forms on our site or by sending us emails).

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data through sources such as job boards or job board aggregators or network sites such as LinkedIn or from other publicly available sources such companies house or internet search engine results.

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). We do not sell or share your personal data to share it with any third party for their own marketing purposes.

You can ask us to stop sending you marketing messages following the opt-out links on any marketing message sent to you or by emailing us at gdpr@flagship-consulting.com at any time.

If you opt out of receiving marketing communications, this opt-out does not apply to our use of your personal data used for other lawful purposes – unless you request us to stop using it and we have no lawful reason to continue using it.

5.  DISCLOSURES OF YOUR PERSONAL DATA

In addition to the disclosures already mentioned in this notice, we may have to share your personal data with the parties set out below:

  • Other companies in our group who provide services to us.
  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA)

7.  DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8.  DATA RETENTION

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.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at gdpr@flagship-consulting.com.

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 or 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.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

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