We at Third Way Recruitment Limited and Montresor Recruitment Limited (“we” or “our” or “us”) want to make sure all the personal information we have collected about you is safe and secure whether we collect it through our websites at www.thirdway.pro and www.montresorlegal.com (“Sites”) or from other sources. This Policy set outs our commitments to you, in compliance with and beyond the General Data Protection Regulation (commonly known as the GDPR) and explains how we collect, store and use your personal information.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisations. If you have any questions about this Policy or what we do with your personal information, their contact details are set out in the “Contact” section below.
We always aim to respect and treat your personal information as if it were our own personal information and use it in an ethical manner.
We always aim to only use your personal information in ways that you agree to, in order to perform our obligations to you to or to others, to comply with our legal obligations or in other ways that most people would expect for a recruitment business.
If you ever feel that we have not lived up to these aims then please let us know. We are always aiming to improve, so your feedback is important to us.
We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information.
Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services or products you may request from us or in providing services or products to our clients, providing you with information you have requested or just managing our relationship with you, whoever you are.
When we hold or use your personal information as a data controller or controller (see below for a description of what this is) we will provide you with a privacy notice which sets out in detail what information we hold about you (such as your contact details, address, etc.), how your personal information may be used and the reasons for these uses, together with details of your rights
Where we collect personal information from you directly, we will provide this privacy notice at the time we collect the personal information from you. Where we receive your personal information indirectly, we will provide this privacy notice when we first contact you, first pass the data to someone else or within a month, whichever is the first to occur of these events
We will usually only provide this privacy notice to you once, generally at the start of our relationship with you. However if the applicable privacy notice is updated substantially, then we may provide you with details of the updated version. You are encouraged to check back regularly for updates.
Copies of our current privacy notices can be found below:
- Client and candidate privacy notice – here
Please note that it is possible for you to be covered by more than one privacy notice, for example you may be a temporary worker. In this example both our candidate privacy notice and our employee privacy notice would apply to you, but for different uses of your personal information.
THE DIFFERENCE BETWEEN DATA CONTROLLERS/PROCESSORS
A data controller or controller is a person who controls how personal information is processed and used. Data controller or controller are two terms that mean the same thing. A data processor is a person who processes and uses personal information in accordance with the instructions of a third party, i.e. the data controller or controller.
This distinction is important. You have certain rights in relation to your personal information, for example the right to be provided with the personal information held about you and details of its use and the right to have certain of your personal information either erased or anonymised, commonly referred to as the right to be forgotten (see below to see what rights you have). These rights can generally only be exercised against a controller of your information.
In most cases we will be a controller of your personal information. In any case where we are not a controller this means that you cannot exercise these rights against us directly (i.e. where we only act as a data processor), but you can do so against the controller (i.e. the person who controls how we process the personal information). In these cases we will endeavour to inform you who is the controller of your personal information so that you can direct any such requests to them.
Also it is only a controller that will provide you with a privacy notice about your personal information, so where we process your personal information as a controller we will provide you with a privacy notice. In any case where we process your personal information as a data processor for a third party, that third party should provide you with a privacy notice which will set out details regarding the processing of your personal information, which should also include the processing to be carried out by us on their behalf.
HOW DO WE USE YOUR PERSONAL INFORMATION?
Where we are a controller we will use your personal information as described in the privacy notice provided to you, but, for example, we may use your personal information to administer any relationship you have with us or to send you information we think you might find useful, provided you have indicated that you are happy to be contacted for these purposes. To see how we use your personal information as a controller, please see our current privacy notices referred to above.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
Details of how we disclose your personal information are set out in the relevant privacy notice provided to you, but generally it is where we need to do so in order to run and operate our business (e.g. where other people process information for us). In these circumstances, we will put in place arrangements to protect your personal information where possible. Outside of that we do not disclose your personal information unless we are required to do so or permitted to do so by law.
If as a controller we transfer personal information about you outside of the UK and the European Economic Area (EEA), we will let you know and ensure that all reasonable security measures are taken and that any third party processers will be required to process the information in accordance with information protection laws and we will notify you in your privacy notice if we are the information controller.
We do not sell, trade or rent your personal information to others for marketing purposes
HOW LONG DO WE HOLD ON TO YOUR PERSONAL INFORMATION?
Further details of how long we hold onto your personal information for are set out in the relevant privacy notice provided to you, but we will only hold your information for as long as is necessary or where you ask us to delete records we may delete it earlier.
The duration for which we retain your personal information will differ depending on the type of information and the reason why it was collected. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements.
WHAT ARE YOUR RIGHTS?
Full details of your rights set out in the relevant privacy notice provided to you, but you are entitled by law to ask for a copy of your personal information at any time. You are also entitled to ask us to correct, delete or update your personal information, to send your personal information to you or another organisation and to object to automated decision making. Where you have given us your consent to use your personal information in a particular manner, you also have the right to withdraw this consent at any time.
To exercise any of your rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contact” section below. You can also unsubscribe from any direct marketing by clicking on the unsubscribe link in the marketing messages we send to you.
You should note that some of your rights may not apply as they have specific requirements and exemptions which apply to them and they may not also apply to all personal information recorded and stored by us. However your right to withdraw consent or object to processing for direct marketing are absolute rights.
If you are unhappy with the way we are using your personal information you can complain to the UK Information Commissioner’s Office or your local data protection regulator. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/ However, we are here to help and would encourage you to contact us first to resolve any complaint you may have
LINKING WITH THIRD PARTY WEBSITES
Our Sites may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.
In addition, if you linked to our Sites from a third-party website, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party website and recommend that you check the policy of that third party website and contact its owner or operator if you have any concerns or questions.
In common with most websites, our Sites log various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring/exit pages and date/time stamps.
We may use this information to analyse trends, administer the Sites, track your movement around the Sites and gather broad demographic information.
Like most websites, certain parts of our Sites use “cookies” to keep track of your visit and to help you navigate between sections and utilise functions on our Sites. A cookie is a small data file that certain websites store on your computer’s hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited. Cookies can also be linked to personal information.
CHANGES TO THIS POLICY
Any changes we may make to this Policy in the future will be posted on our Sites and, where appropriate, notified to you by e-mail. When we change this Policy in a material way, we will update the version date at the bottom of this page. Please check back frequently to see any updates or changes to this Policy and should you object to any alteration, please contact us as set out in the “Contact” section below.
In the event of any query or complaint in connection with the information we hold about you, please contact our Data Protection Compliance Manager who can be contacted at email firstname.lastname@example.org or write to us at Data Protection, Thirdway/Montresor, 25 North Row, London, W1K 6DJ.
Version Date: 22 May 2019