Recruitment Privacy Policy

Introduction

This privacy notice (the “Privacy Notice”) applies to any individual (“you”, “your, “Candidate”) who applies to Charlton Morris Limited, incorporated and registered in England and Wales with company number 08686363 whose registered office is at 34 Boar Lane Leeds, LS1 5DA ("Charlton Morris" "us" or "we") for a job opportunity to work with Charlton Morris and/or a job opportunity to work with a third party (“Partner”)whose opportunity is made available through Charlton Morris’ services as a recruitment business (in each case an “Opportunity”, or collectively “Opportunities”).   

The Privacy Notice sets out the information that must be provided by Charlton Morris as a “Data Controller” to each Candidate that supplies it with information that qualifies as Personal Data (as defined below), and it is separate and in addition to the https://www.charltonmorris.com/privacy-policy/ (the “Website”) Privacy Policy. 

Terms used in this Privacy Notice

 “Personal Data”, “processor”, and “processing” (or any equivalent terms), each have the meaning as set out in the Data Protection Law.

Our Contact Details

If you have any questions about this Privacy Notice or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Charlton Morris Limited

Email address: kris.holland@charltonmorris.com

Postal address: 34 Boar Lane, Leeds, LS1 5DA

Telephone number: 0113 3452266

Alternatively, if you are located inside the European Economic Area (EEA) please contact our representative in the EEA at:

timbell@datarep.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk) or any other competent data protection authority in the relevant jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the other relevant authority so please contact us in the first instance.

Changes to the Privacy Notice and your duty to inform us of changes

We may amend this Privacy Notice from time to time to accurately reflect the regulatory environment and our data collection and disclosure practices. Accordingly, you should review this Privacy Notice periodically. When we change this Privacy Notice in a material way, we will update the “last updated” date at the top of this Privacy Notice. Changes to this Privacy Notice are effective when they are posted on this page.

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.

The Personal Data we collect and how we collect it

Our “Recruitment Process” consists of a Candidate applying for an Opportunity or requesting for Charlton’s Morris’ assistance with selecting Opportunities; through to determining a Candidate’s suitability; communications with that Candidate and Partners as applicable; and selection and appointment of a Candidate in respect of the same, as applicable. In conducting the Recruitment Process we collect the following Personal Data:

• Information you provide during the Recruitment Process. You may provide us with Personal Data during the various stages of the Recruitment Process, for example, when you submit an online application for an Opportunity on the Website, or when you are being interviewed for an Opportunity. Such Personal Data includes: Contact information, such as full name, address, phone number, email address; skills history, such as curriculum vitae, cover letter, work experience, education; job requirements, such as salary, role and scope, and current availability; identity verification information, such as passport number, visa requirements, and diversity data; references and links to public profiles e.g. LinkedIn; and any other information you volunteer to us during the Recruitment Process.  
• Information third parties provide during the Recruitment Process. We also may obtain Personal Data about you from third parties, such as from your referees, or identity verification providers. Where permitted by law, we may request background or credit checks from public authorities or financial institutions to evaluate your eligibility for employment.
• Information we automatically collect during the Recruitment Process. When you apply for an Opportunity through the Website, we may collect Personal Data that is automatically sent to us by your computer, mobile phone or other device. The information sent to us includes, but is not limited to, the following: data about the pages you access on our Website, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information, including your browser type and traffic to and from our Website.

Sensitive Data. We may collect and process Sensitive Data about you in order to assess suitability for an Opportunity, but only where permitted by law. This may include information about your health, details of any disability, details of any offences you have committed or are alleged to have committed and whether you are a member of any professional or trade associations.  

Our Purpose for processing the Personal Data

We will only use your Personal Data when the law allows us to, and in order to conduct the Recruitment Process for you and our Partners. More particularly this includes:

• carrying out our obligations arising from any contracts between Charlton Morris and Candidates, or between Charlton Morris and our Partners;
• providing Candidates with information about Opportunities;
• matching Candidates with Opportunities, including: (i) processing Candidate applications; (ii) assessing Candidate suitability for the Opportunities (including but not limited to conducting any legally required background or eligibility checks) and providing to the applicable Partner as applicable; (iii) conducting any interview processes; (iv) communicating with Candidates about such Opportunities; and (iv) completing any necessary documentation where a Candidate is appointed e.g. contract of employment.  
• protecting the security of our property and systems, enforcing company policies, and permitting the functionality of the applications submissions process for Opportunities;
• To comply with applicable laws and protect our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, auditing, and investigative and disciplinary purposes (including disclosure in connection with legal process or litigation), monitoring the satisfaction of users of our service and market research (of e.g. salaries); and  
• to conduct a review of our equal opportunities profile in accordance with applicable legislation.

We will only use your Personal Data for the purpose for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need 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.

Please note that 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.

Our legal basis for processing your Personal Data

We only process your Personal Data when we have a legal basis to do so as follows:

• Legitimate interests. We process the Personal Data because it is necessary to properly conduct the Recruitment Process and it is in our legitimate interests both for the purpose of properly recruiting suitable employees for Charlton Morris, and to conduct the Recruitment Process and provide, monitor and improve our recruitment services.
• Contract. The processing of Personal Data may additionally be necessary to comply with any contracts that Charlton Morris has in place with Partners offering Opportunities on our Website or with you should we enter into a contract in connection with the carrying out the Recruitment Process.
• Law. Charlton Morris may also process your Personal Data where we are required to by law (for example, to comply with auditing, tax or employment law obligations). 
• Consent. In the case of Sensitive Data, we may process such Sensitive Data only where such information is legally required and permissible to use to conduct the Recruitment Process. Where this is not the case, we will ask for your express consent to process such Sensitive Data. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time (as set out below).

If you do not provide the Personal Data necessary, object to or withdraw your consent (where applicable) for the processing of Personal Data, we may in individual cases not be able to conduct the Recruitment Process properly.  For example, if you do not provide evidence of your work history, we will not be able to assess your suitability for an Opportunity.

Disclosures of your Personal Data

We may share your Personal Data as follows:

• In the Recruitment Process. We may share your Personal Data across Charlton Morris and with government authorities and/or law enforcement officials where required as set out above under “Our Purpose for processing the Personal Data”;
• Compliance with laws. If mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws;

• Third Parties. We may share your Personal Data with our Partners who have provided Opportunities that you have either applied for or have provided Opportunities for which you have been submitted on your request.

We may also share your Personal Data with third-party suppliers and organisations to assist us with the Recruitment Process and enable us to provide recruitment services. We may share Personal Data with the following parties:

• Bulhorn – to assist us with CRM used to support our company operations, storage of both client and candidate data;
• Microsoft – to manage and store documents and internal communcations;
• Odro – for video messagaging;
• Slack – for communications and the sharing of documents;
• A change in our business. With 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 privacy policy.

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.

How long we keep your Personal Data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see “Your Rights in respect of your Personal Data” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Transferring your Personal Data

Some of our third parties may be based outside the UK/EEA so their processing of your Personal Data will involve a transfer of data outside the UK or EEA.

Whenever we authorise a transfer of your Personal Data outside of the UK and EEA, we ensure a similar degree of protection is afforded to it by using specific contracting frameworks approved by the UK government and European Commission which give Personal Data the same protection it has in the UK and the EEA. If you require further data on the specific mechanism used by us when transferring your Personal Data out of the UK and EEA, please contact us using the contact details provided above.

Data Security

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.

Your Rights in respect of your Personal Data

Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:

• 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.
• Request correction of the Personal Data that we hold about you. 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.
• Request erasure of your Personal Data. 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.
• 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.
• Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your Personal Data to another party. 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.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to conduct the Recruitment Process or provide other services. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the contact details provided above.

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. Alternatively, we could 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 could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.