2. Who we are and how to contact us
3. The data we collect about you
4. How we collect personal data
5. How and why we use personal data
7. Automated decision-making
8. Change of purpose
9. If you fail to provide personal data
11. Who we disclose personal data to
12. International transfers
13. Data security
14. Data retention
15. Your rights in respect of your personal data
16. Changes to your personal data
We are a “data controller” for the purposes of data protection legislation. This means that we are responsible for deciding how we hold and use personal information about you. We are committed to protecting and respecting your privacy.
By using our site and services, we may collect, use, store and transfer different kinds of personal data about you. In respect of all users of our site, the personal data we may collect includes information you send to us when making an enquiry and electronic data which is processed when accessing or browsing our site. If you are using our site or our services as a job applicant ("applicant"), we may also collect your personal data when you register to use the Portal, apply for a job via the Portal or sign up to receive marketing emails from us, for example. We may also collect your personal data from third party sites when you respond to a job advertisement we have placed on a third party site or when you upload your details to a third party site to indicate you are looking for work. If you are using our site on behalf of one of our business clients (“client representative”), the personal data we collect about you personally is likely to be more limited, but could include, for example, the login details you use to access the Portal and contact details you provide us with .
Our site is not intended for children and we do not knowingly collect data relating to children.
We Searchability (UK) Ltd are a limited company registered in England and Wales under company number 7977871 and have our registered office at Booth Street Chambers, 32 Booth Street, Ashton-under-Lyne OL6 7LQ.
To contact us, please email firstname.lastname@example.org or telephone us on 01244 567 567.
Personal data, or personal information, means any information relating to an identifiable individual. It does not include any data or information which relates to a person that cannot be identified or where the person's identity has been removed (ie anonymous data). It also does not include information relating solely to a business or other organisation, rather than to a person.
By using our site, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
We do not collect any special categories of personal data about you, without gaining your explicit written consent (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We will only collect information about criminal convictions and offences (including via DBS checks) where such processing is authorised by law and necessary for the role you have applied for. We shall inform you before collecting any such data.
The majority of the personal data we hold about you is collected when you correspond or interact with us directly (via our site, the Portal or social media, by post, phone, email, telephone or otherwise).
This includes personal data you provide when you:
The categories of personal data we collect in this way include Identity, Contact, Profile, CV, Application, Social Media, Financial, Usage and Marketing and Communications Data.
When you interact with our site, our systems will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy and section 10 below for further details.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
5. How and why we use personal data
We will only collect and process your personal data where we have a legal basis to do so. The legal basis will vary depending on the manner and purpose for which we are collecting your personal information. Most commonly, we will use your personal data in the following circumstances:
We have set out in the table below a description of the ways we plan to use your personal data, and which of the legal bases we shall rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data on the basis of more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you require further detail about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To set up, manage access to, and maintain the security of, your online account for our site and/or the Portal (for users of the Portal)||Identity, Contact, Profile, Technical and Usage Data||Necessary for our legitimate interests (to conduct our business and perform our contracts with clients)Consent – given at the time of registering an online account for our site and/or the Portal|
|To provide recruitment services to clients by displaying job adverts on our site or third party job boards and via the Portal, which may include assisting with the processing of applications (including CVs) submitted by individuals via the Portal in response to such job adverts||Identity, Contact and Profile Data (of client representatives)||Necessary for our legitimate interests (to conduct our business and perform our contracts with clients)|
|In the case of a client representative, to liaise with you in connection with job applications and manage the client’s Portal account||Identity, Contact and Profile Data (of client representatives)||Necessary for our legitimate interests (to conduct our business and perform our contracts with clients)|
|In the case of client representatives, to process financial payments from clients for use of the Portal and supply of other services||Identity, Contact, Profile, Financial and Technical Data||Our legitimate interests (to conduct our business, process payments for services and perform our contracts with clients)|
|To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, Contact, Usage and Technical Data||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you based upon your content preferences||Identity, Contact, Profile, Usage and Marketing and Communications Data||Necessary for our legitimate interests (to develop our services and grow our business)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||Identity, Contact Technical and Usage Data||Necessary for our legitimate interests (to define types of customers for our services, to keep our business updated and relevant, to develop our business and to inform our marketing strategy)|
|To deal with and respond to queries submitted to us via our site, social media accounts, by post, email or by telephone||Identity, Contact, Social Media, Profile, Application and Marketing and Communications Data||Consent – given at the time of contactOur legitimate interests (to conduct our business and correspond with applicants and clients)|
|To provide use of the functionality offered by the Portal and to provide associated consultancy services to clients||Identity, Contact, Social Media, Profile, Application and Marketing and Communications Data|
Marketing and Recruitment communications from us: We may send you marketing and Recruitment communications if you:
Third party marketing: We will only share your personal data with another company for marketing purposes if you have expressly consented to us doing so.
Opting out: You can ask us and/or third parties to stop sending you marketing or recruitment communications at any time, by:
We do not currently use purely automated decision-making.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we wish to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Where we need to collect personal data from you in order to comply with our legal obligations or to perform a contract we have with you or your employer/hirer and you fail to provide that data when requested, we may not be able to perform the relevant contract (for example, to engage you as a contractor or provide your employer with services). In this case, we may have to cancel the relevant contract.
We may share personal data with the third parties set out below for the purposes set out in the table above. These third parties process your personal data on our behalf in connection with the performance of certain services for us. :
|Name of Service Provider||Platform||Types of Personal Data|
|KeyBridge||IT Support Provider||Identity, Contact, profile, CV, Application, Financial, Marketing, Communications Data|
|LuvMedia||Website Host||Identity, Contact, CV, Profile, Application, Technical and Usage Data. This type of personal data is only shared through the website host as a processor if a data subject creates an online account with us.|
|Broadbean||Data Analytic Software||Identity, Contact, CV and Application Data|
|Bullhorn & Kyloe & Herefish||Recruitment Software||Identity, Contact, Profile, CV, Application, Financial, Marketing and Communications Data.|
We require all our data processors to respect the security of your personal data and to treat it in accordance with the law. We do not allow our data processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions as set out in our data sharing agreements.
Many of our external third parties are based outside the Economic European Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in order to develop our business methods and strategy or for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If you are an applicant, we will retain your personal data for a period of 36 months from the point of last meaningful contact with you. Meaningful contact includes any email or telephone correspondence with you that has resulted in submission of an updated CV or a change to your personal information. We will keep this under review and may periodically delete some of your personal data which we no longer require for the purposes set out in the table above.
In some circumstances we may be entitled to retain your data for a longer period where we are under a legal obligation to do so, for example in the event of a legal dispute. We will also need to keep a record of your contact details if you have opted-out of receiving marketing communications from us to ensure we do not send these to you in future.
You have the following rights in respect of the personal data that we process about you (where we determine the purpose and means for which that personal data shall be processed):
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data (such as your contact details) changes during your relationship with us.