Current version of policy V4.0
Updated: 21st April 2021
This website is not intended for children and we do not knowingly collect data relating to children.
For the purpose of the Data Protection Act 2018 and the UK General Data Protection Regulation (Retained Regulation (EU 2016/679), the data controller is Jumar Solutions Limited (Company No. 02333415) or Jumar Technology Limited (Company Number 11786401) of Jumar House, Pinewood Business Park, Coleshill Road, Solihull, West Midlands B37 7HG. This means that we are responsible for deciding how we hold and use personal information about you.
1. DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
· Used lawfully, fairly and in a transparent way;
· Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
· Relevant to the purposes we have told you about and limited only to those purposes;
· Accurate and kept up to date;
· Kept only as long as necessary for the purposes we have told you about; and
· Kept securely.
2. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
We aim to provide excellent services to our customers and candidates. In the case of providing employment business services, we aim to create the best match between open vacancies and candidates. We aim to create the best possible solution to meet the requirements of our clients. To do this, we will need to process data about you.
We hold and process your data in pursuit of our legitimate interest in providing services to our candidates and clients. “Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). It is in our legitimate interests to decide whether to appoint you or put you forward for a particular role because it is beneficial to our business to seek to fulfil vacancies. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
In the case of the provision of employment business services, once we place a candidate with one of our clients, the data is held as part of the contractual and legal obligation that we have as a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Business Regulations 2003.
3. THE DATA WE COLLECT ABOUT YOU
Personal data (or personal information) means any information about an individual from which that person can be identified. It does not include data where the identity of the individual has been removed (anonymous data). We may collect, use, store, transfer and process different kinds of personal data about you including the following:
· Identity data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
· Contact data including address, email address and telephone number;
· Technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Websites. This also includes details of your visits to our Websites including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access as detailed in our cookies policy;
· Data from automated emails, which record – for example – whether the email has been opened, and which may or may not be recorded against your personal record;
· Usage data including information about how you use our Websites and services; and
· Employment data including details about your employment history, education and pay and/or salary details.
We do not intentionally collect any sensitive or special categories of personal data (as defined in the applicable data protection legislation) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We may collect some of this data anonymously (where you agree to provide it) for statistical monitoring purposes. Nor do we intentionally collect any information about criminal convictions and offences. However, if you provide us with any sensitive personal data as a part of a job application or screening process, if required for a particular job, we will request your explicit consent to process this data.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g. to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the relevant time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
– Direct interactions
You may give us your personal data by filling in forms on our website, www.jumar.co.uk (or any data historically provided through our legacy websites (www.jumar-solutions.com” and/or “www.jumar-recruitment.com” and/or “www.jumar-technology.com”) (“Websites”) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide (whether directly or indirectly via third parties such as those listed below) when you:
· submit your curriculum vitae (“CV”)and/or covering letter;
· submit your application form;
· provide information during any interview or phonecall with us;
· download documentation or other literature such as whitepapers from our Websites;
· apply for a particular role;
· request information about services;
· enter a competition, promotion or complete a survey;
· report a problem with our Websites;
· create an account on our Websites;
· interact with an email sent to you by us;
· requesting marketing to be sent to you; or
· give us feedback or contact us.
– Third parties or publicly available sources
We will receive personal data about you from various third parties and public sources including (but not limited to) the below:
· Companies House;
· Job boards and online CV libraries with which we have a contract (e.g. Jobsite, Jobserve, Totaljobs);
· Data aggregating providers (e.g. Idibu and Pocket Recruiter); and
· LinkedIn and other professional networking sites.
– Automated technologies or interactions
As you interact with our Websites, we will automatically collect technical data about your equipment, browsing actions and patterns. We will collect this personal data by using cookies, server logs and other similar technologies. We typically use Google Analytics or similar technologies for this.
5. THIRD PARTY LINKS
6. HOW WE USE YOUR PERSONAL INFORMATION
We only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following ways:
– To perform our services, which may involve us:
· notifying you of relevant job opportunities as part of our jobseeker services;
· assessing your skills, qualifications and suitability for particular vacancies;
· carrying out background and reference checks (where applicable);
· communicating with you about the hiring process;
· keeping records related to our hiring processes;
· complying with our legal or regulatory requirements;
· using your personal data to compile short-lists of relevant candidates for certain vacancies; or
· providing your details (including your CV and other information provided to us) to employers (who are our clients) where you have submitted such information in response to job vacancies displayed on the Websites, job boards or LinkedIn and similar (this will only be done with your consent),
· Where we need to comply with a legal obligation
· To perform the contract we are about to enter into or have entered into with you
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
· To ensure that content from our Websites is presented in the most effective manner for you and for your computer
· To provide you with information, products or services that you request from us
· To allow you to participate in interactive features of our service, when you choose to do so
· To notify you about changes to our service.
We will never share your personal data with third parties for marketing purposes.
7. DISCLOSURES OF YOUR PERSONAL INFORMATION
We will not transfer your personal data outside the United Kingdom.
We may share your personal data with the parties set out below:
· to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable);
· external third parties such as Bullhorn (Recruitment CRM), Idibu (Job application tool), Pocket Recruiter (candidate sourcing tool), Microsoft (Office 365) and any external live chat application; and
· third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
We may disclose your personal information to third parties:
· where you have submitted such information in response to job vacancies displayed on our Websites, to the Employers to which the vacancy relates once you have given us permission;
· if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements;
· to protect the rights, property, or safety of us, the Websites, our users and any third party we interact with the to provide the Websites; or
· who provide necessary cloud-based systems (e.g. CRM) that we use to provide our services to you.
We will not sell your data to any third parties.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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.
8. RETENTION OF YOUR PERSONAL DATA
We retain data on candidates for a period of two years from our most recent meaningful contact, unless you request otherwise. This period is extended to six years, if we place you in a role. If that role is a contract position, this is six years from the end of the last placement. If it is a permanent placement, it is for a period of six years from the start date of your employment with our client.
If you apply for a role via our Websites or via a third-party’s website, we will hold your data for up to two months – during which time we will make reasonable endeavours to contact you. If we make contact and mutually agree that we will retain your details for that role and/or any subsequent future roles, the two-year policy will apply as above.
If we do not manage to make contact, or if we mutually agree not to continue holding your data, we will delete it within a month.
If you exercise your right to erasure under the applicable data protection regulation, we will retain all information we are legally obligated to do so (such as employment contract data or financial payment), for the period that is set out by that legal obligation. We may also keep your name and the bare minimum of contact details so that we do not contact you or re-enter your details inadvertently in the future. Where technology allows, any data that we retain following an erasure request, will be anonymised.
When we register a new candidate on our database, we will send a copy of our data processing document entitled ‘Jumar and your data’ which gives further details on data retention periods and our data protection policies.
9. IP ADDRESSES AND COOKIES
Please see our cookies policy.
10. DATA SECURITY
The transmission of any information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data whilst being transmitted to our Websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights are as per the applicable data protection legislation, namely:
· right to be informed about how and why your personal data is being used and/or processed;
· right to request access to your personal data (commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it);
· right to request of rectification of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
· right to request erasure of your personal data (right to be forgotten). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
· right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
· right of data portability/to request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
If you wish to exercise any of the rights set out above, please contact us using the details below.
We keep this Policy under regular review and we reserve the right to modify this Policy at any time. Any changes we make in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you have any queries about this policy, please contact your Jumar representative in the first instance. If you do not know their details, please contact firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.