Co-Venture Limited (a company registered in England and Wales, registered number 07156675, trading as SuperGrad) (“SuperGrad”, “we” or “us”) is committed to protecting and respecting the privacy of all the individuals for whom we collect and use personal data.
This notice, together with our Terms & Conditions and any other related documents or notices, sets out the basis on which any personal data SuperGrad collect from you, or that you provide to us, will be held and processed by us.
The General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The new Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Your rights under GDPR are set out in this notice and apply from 25 May 2018.
Who We Collect Personal Data From?
SuperGrad collect the personal data of the following types of people:
- CANDIDATES – prospective and placed candidates for permanent or temporary roles, including applicants for all roles advertised or promoted by SuperGrad and people who have supplied their CV or profile to SuperGrad not in relation to a specific job;
- WEBSITE USERS – any individual who visits the SuperGrad website / https://www.supergrad.org.uk (“Website”);
- CLIENTS – includes contacts within prospective and live clients to whom SuperGrad provides services in the course of its business;
- EMPLOYEES – includes any individual employed by SuperGrad on a permanent or temporary basis (or those who have accepted an offer to be employed);
- OTHERS – other individuals whom SuperGrad may contact, for example referees or emergency contacts for staff. We will only contact them in appropriate circumstances.
What Kind Of Information Do We Collect and How Do We Collect It?
CANDIDATES: SuperGrad collects personal data when you correspond with us by phone, e-mail, SMS and through our website. It includes information you provide when you:
- Register as a candidate by submitting your CV
- Apply for specific jobs
- Subscribe to receive our email newsletter
- Request a job to be emailed to you
- Refer colleagues or friends as part of our referral program
- Enter a competition or take part in a survey
- Register to attend a SuperGrad-organised event
The information you give us, or SuperGrad collect about you, may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, and your curriculum vitae (CV).
SuperGrad may also obtain personal data about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In these cases SuperGrad will inform you, by sending you this privacy notice within a maximum of 30 days of collecting the data, of the fact SuperGrad hold personal data about you.
WEBSITE USERS: SuperGrad automatically collect certain information when you visit our Website. This includes technical information, such as the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, operating system and platform. We also collect information about your visit, including the full Uniform Resource Locators (URL) of each page visited, clickstream to and through our Website including date and time, jobs visited and searched for, download errors, length of visits to pages, and any information submitted through forms.
CLIENTS: To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We collect your personal data either directly from you, from third parties (e.g. our Candidates) or other limited sources (e.g. online and offline media).
SUPPLIERS: We use and store the personal data of individuals within your organisation, and keep records of our conversations and meetings with them, in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We collect your personal data either directly from you, from third parties (e.g. our Clients) or other limited sources (e.g. online and offline media).
EMPLOYEES: We hold and process a range of personal data including, but not limited to, your name, address, e-mail addresses and phone numbers, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, your curriculum vitae (CV) and details of your current bank account.
OTHERS: Sometimes we are provided with and/or collect the details of other individuals, for example for a candidate reference or an emergency contact for an employee.
How Do We Use Your Personal Data?
CANDIDATES: As you would expect, the main reason for using your personal data is to provide recruitment services, which will likely include, but not be limited to, the activities listed below. Using your personal data in this way is deemed necessary for our legitimate interests. In certain circumstances you have the right to object to this.
- Storing your details on our database so that we can contact you in relation to recruitment activities;
- Assessing data about you against vacancies which we think may be suitable;
- Sending details about you to Clients in order to apply for jobs and / or assess your eligibility for jobs;
- Enable us to send you our newsletter if you have subscribed for this service;
- Carrying out our obligations arising from any contracts entered into between us;
- Carrying out our obligations arising from any contracts entered into between SuperGrad and third parties in relation to your recruitment;
- Facilitating our payroll and invoicing processes;
- Carrying out customer satisfaction surveys;
- Verifying details you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
- Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties;
- Processing your data to enable us to send you targeted, relevant marketing information or other communications which we think are likely to be of interest to you, for example about job opportunities, events we are running or articles we have written that we believe will be of interest to you.
We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in.
Soft opt-in consent is a specific type of consent which applies 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 other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent. You have the right to withdraw your consent at any time.
All our marketing is based on what we think will serve our Clients and Candidates best, but we know we won’t always get it right for everyone. Please contact us immediately if you feel that your interests are not being best served.
CLIENTS: The main reason for using personal data of our Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with any legal requirements. This is likely to involve identifying Candidates who we think will be the right fit for you or your organisation. The more information we have, the more bespoke we can make our service.
SUPPLIERS: The main reason for using the personal data of our Suppliers is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with any legal requirements. Typically we need the contact details of relevant individuals at your organisation so that we can communicate with them. We may also need other information such as bank details so that we can pay for the services you provide.
EMPLOYEES: we hold and process your personal data in order to effectively onboard you into SuperGrad and fulfil our duties as your employer whilst you are with us, which includes holding your financial details, so that we can pay you.
OTHERS: If you have been put down by a Candidate or a prospective member of Staff, as one of their referees, we use your personal data in order to contact you for a reference. If a Candidate or Staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency.
Who Do We Share Your Personal Data With?
CANDIDATES: Where appropriate we may share your personal data, in various ways and for various reasons, with the following categories of people:
- Potential employers (our Clients) and other recruitment agencies/organisations to increase the prospects chances of finding you employment;
- Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
- Third parties who SuperGrad have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate;
- Third party partners, job boards and job aggregators when SuperGrad consider this will improve the chances of finding you the right job;
- Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
- Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our systems);
- Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
- Marketing technology platforms and suppliers;
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 relevant to you.
CLIENTS: We will share your data primarily with Candidates in the process of presenting you as a prospective employer to them and in arranging interviews and so forth to facilitate this process. We may also share your information with associated third parties such as our service providers to help us meet these aims.
SUPPLIERS, EMPLOYEES & OTHERS: Unless you specify otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.
How Do We Safeguard Your Personal Data?
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
- All of your details, including your CV, records relating to conversations, emails and so forth are stored in the cloud and protected from unauthorised access by password;
- Any hard copies of your details are shredded immediately after use;
- All of the clients we work with are contractually obliged to respect GDPR;
- All of the suppliers we use are contractually obliged to respect GDPR;
If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact us can be found below.
How Long Do We Keep Your Personal Data For?
We will delete* your personal data from our systems if we have not had any meaningful contact* with you (or, where appropriate, the company you are working for or with) for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
For those Candidates whose services are provided via a third party company or other entity, “meaningful contact” with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.
* Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.
* Meaningful Contact – communication between us (either verbal or written), or when you are active engage with our online services. This could be, for example, if you submit your CV (via email or our website or through other digital channels where a job may be advertised), or communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.
How Can You Access, Amend Or Take Back The Personal Data That You Have Given To Us?
One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
If you have any queries with respect to your rights regarding the personal data that SuperGrad may hold about you, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right To Object:
You have the right to object to us processing your personal data where we do so for one of the following reasons:
- our legitimate interests;
- to enable us to perform a task in the public interest or exercise official authority;
- to send you direct marketing materials;
- for scientific, historical, research, or statistical purposes.
The legitimate interests and “direct marketing” categories above are the ones most likely to apply to our Candidates, Website Users, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
- we can show that we have compelling legitimate grounds for processing which overrides your interests;
- we are processing your data for the establishment, exercise or defence of a legal claim.
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Right To Withdraw Consent:
Where we have obtained your consent to process your personal data for certain activities (for example, you have subscribed to our newsletter via our Website), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
Data Subject Access Requests (DSAR):
You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always explain the reasons for doing so.
Right To Erasure:
You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet at least one of the following criteria:
- the data are no longer necessary for the purpose for which we originally collected and/or processed them;
- where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
- it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
- we are processing the data because we believe it necessary to do so for our legitimate interests, but you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for one of the following reasons:
- to exercise the right of freedom of expression and information;
- to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
- for public health reasons in the public interest;
- for archival, research or statistical purposes; or
- to exercise or defend a legal claim.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
Right To Restrict Processing:
You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either:
- one of the circumstances listed below is resolved;
- you consent to further processing; or
- further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
- where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
- where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
- where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; or
- where we have no further need to process your personal data, but you require the data to establish, exercise, or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
Right To Rectification:
You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right Of Data Portability:
You have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer the personal data SuperGrad hold about you to another platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data. Alternatively, we may directly transfer the data for you. This right of data portability applies to:
- personal data that we process automatically (i.e. without any human intervention);
- personal data provided by you;
- personal data that we process based on your consent or in order to fulfil a contract.
Right To Lodge A Complaint With A Supervisory Authority:
You also have the right to lodge a complaint with your local supervisory authority, The Information Commissioner’s Office (ICO). The ICO can be contacted in the following ways:
By phone: 0303 123 1113
By email: email@example.com
By post: ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Our Legal Bases For Processing Your Data
There are three legal bases for processing your personal data:
Article 6(1)(f) of the GDPR states that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data”.
We think that collecting and using your personal data as defined above (in What Kind Of Information Do We Collect and How Do We Collect It? and How Do We Use Your Personal Data?) helps SuperGrad to deliver you a more tailored, efficient service. We therefore think it’s reasonable to collect and use your personal data in this way. For example, if you are looking for employment or have posted your CV on a job board or professional networking site, you will be happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies. Your prospective employer may also want to double-check any information you’ve given us (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We believe that these examples and other similar situations constitute legitimate interest.
Meeting our own obligations under the law also constitute a legitimate interest of ours. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
However, you do have the right to object to us processing your personal data on this basis.
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your personal data, this consent will be opt-in consent or soft opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her”. In plain language, this means that:
– you have to give us your consent freely, without us putting you under any type of pressure;
– you have to know what you are consenting to, so we will have given you enough information to make that decision;
– you should have control over which processing activities you consent to and which you don’t, something which you can do by contacting us and requesting changes at any time; and
– you need to take positive and affirmative action in giving us your consent – in most circumstances, we will provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion and we will keep records of the consents that you have given in this way.
In some cases, we will be able to rely on soft opt-in consent and will be allowed to contact you regarding services and with information related to the recruitment services we provide as long as you do not actively opt-out from these communications.
You have the right to withdraw your consent to these activities at any time.
Establishing, exercising or defending legal claims:
Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows for this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
By post: The Data Protection Manager, SuperGrad, Three Tuns House, 109 Borough High Street, SE1 1NL
By email: firstname.lastname@example.org
Please note that we may keep a record of your communications to help us resolve any issues which you raise.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.