Privacy Policy

Privacy Policy (last updated 20/03/2024)

1.Introduction

1.1 Gillespie Manners Limited are committed to protecting the personal information and privacy of the candidates we represent and the clients for whom we work. 

1.2 This Information Notice, together with any other documents referred to in it, sets out the basis on which any personal data that we collect from or about you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we treat it. The collected data will be used lawfully, fairly and in a transparent way.

1.3 For the purpose of the General Data Protection Regulation, the data controller is Gillespie Manners Limited (company number 07139334), whose registered office is at Chiltern House, 184 High Street, Berkhamsted, Hertfordshire, HP4 3AP.

Our EU Representative:

Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is: Instant EU GDPR Representative Ltd.

Adam Brogden contact@gdprlocal.com

Tel +35315549700

INSTANT EU GDPR REPRESENTATIVE LTD

Office 2,

12A Lower Main Street, Lucan Co. Dublin

K78 X5P8

Ireland

 

1.4 We may update this Information Notice from time to time. Any changes we make in the future will be posted on our website at www.gillespiemanners.com. Please check back regularly to see any updates or changes.

2.0 Legal Basis for Processing Personal Data under GDPR

We may process personal data about our stakeholders (by which we mean current and former candidates, clients and any other person who has contact with us) in a range of ways, and for a range of purposes. The legal basis for these eventualities is listed below;

 

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

 

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

3.0 Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information we have on you. This also enables you to receive a copy of the Personal Data We hold about you.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of Your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please 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 your consent. You have the right to withdraw your consent on us using your Personal Data. If You withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

4.0 Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you within 14 days.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data.

4.1 If you wish to invoke any of the above rights, please notify us via email at info@gillespiemanners.com. Please include the words DATA PRIVACY REQUEST in the subject line of your email, or at the top of your letter. Alternatively, the contact details of our EU Representative are below:

Our EU Representative:

Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is: Instant EU GDPR Representative Ltd.

Adam Brogden contact@gdprlocal.com

Tel +35315549700

INSTANT EU GDPR REPRESENTATIVE LTD

Office 2,

12A Lower Main Street, Lucan Co. Dublin

K78 X5P8

Ireland

4.2 If you remain dissatisfied, you can make a complaint about the way we process your personal information to the supervisory authority. In the United Kingdom, the supervisory authority is the Office of the Information Commissioner, full contact details for which can be found at https://ico.org.uk/global/contact-us/

4.3 Contact details:  You can contact us in the following ways if you have any questions or concerns about personal data and privacy matters:

info@gillespiemanners.com
01442 878138
Chiltern House, 184 High Street, Berkhamsted, Hertfordshire, HP4 3AP

4.2 Please include the words DATA PRIVACY REQUEST in the subject line of your email, or at the top of your letter.

5.0 Particulars of Processing

Category of data subject

Candidates

Categories of personal data that we process

Name, address and other contact details
Date of birth
Nationality (and work permit details where relevant)
Academic history and qualifications
Career history, referee details and references
Salary and package

Purposes of the processing

We process the personal data listed above for the purposes of operating a recruitment service, providing services to both candidates and employers.

Lawful basis of processing

The lawful basis of processing is (a) legitimate interest. We have a legitimate interest in processing such data so that we can match relevant roles to you and discuss this with you , or (b) that the processing is undertaken with the consent of the data subject, and/or (c) that the processing is necessary for the performance of a contract to with the data subject is party, or in order to take steps at the request of the data subject prior to entering in to a contract .   

Recipients of the personal data

The personal data that we hold about candidates will be disclosed to prospective employers, where we have the specific permission of the candidate to such disclosure.

The personal data will be securely stored by Ikiru People Ltd, a company registered in England under company number 02043300 with its registered office at 12 Cedarwood , Crockford Lane, Chineham Business Park, Basingstoke, RG24 8WD, United Kingdom and trading as Filefinder by Ikiru People. Filefinders’ services include the provision of software that allows search firms to store contact details and professional information for the search firms’ own candidates and clients. The storage is carried out under a written contract that includes safeguards for the rights and freedoms of data subjects.

Overseas transfers

If the role being applied for is based overseas, candidate information will be passed on to the overseas client with permission from the candidate

Duration of processing

Unless the candidate consents to their information remaining on our database, personal data will continue to be processed for 1 year following a lack of active engagement

Is the provision of this personal data a statutory or contractual requirement, or a requirement necessary to enter into a contract? If so, is the data subject obliged to provide the personal data in question?

What are the possible consequences of failure to provide such data?

You are not obliged to provide the personal data in question. However, if you do not provide the personal

data, we may be unable to match your details up with potential employers.

Is there any automated decision-making done using the personal data (including profiling)?

If so, (a) what logic is involved, and what are the significance and envisaged consequences of the processing for the data subject?

During the process, candidates may be subject to psychometric profiling.
This profiling serves only to aid recruitment process, and ensure candidates and employers are matched correctly.
This profiling is not strictly required, however, if candidates do not carry out the profiling process, we may be unable to match their details with potential employers and gauge their suitability for the role.
None of the profiling used is automated.

Plans for further processing

Unless given permission by the candidate, no further processing will be carried out.

 

Category of data subject

Clients

Categories of personal data that we process

Name, address and other contact details
Nationality (and work permit details where relevant)
Position in their company
Company information (name, industry, website, number)
Role being recruited for
Information on the role (salary range, desired candidates, etc)

Source of information

The above personal data is received direct from the data subject.

Purposes of the processing

We process the personal data listed above for the purposes of operating a recruitment service, providing services to both candidates and employers.

Lawful basis of processing

The lawful basis of processing is (a) legitimate interest. We have a legitimate interest in processing such data so that we can match relevant candidates to your  roles discuss this with you , or (b) that the processing is undertaken with the consent of the data subject, and/or (c) that the processing is necessary for the performance of a contract to with the data subject is party, or in order to take steps at the request of the data subject prior to entering in to a contract .  

Recipients of the personal data

The personal data that we hold about clients will be disclosed to prospective candidates, where we have the specific permission of the client to such disclosure.

The personal data will be securely stored by Ikiru People Limited, a company registered in England under company number 02043300 with its registered office at 12 Cedarwood , Crockford Lane, Chineham Business Park, Basingstoke, RG24 8WD, United Kingdom and trading as Filefinder. Filefinders’ services include the provision software that allows search firms to store contact details and professional information for the search firms’ own candidates and clients. The storage is carried out under a written contract that includes safeguards for the rights and freedoms of data subjects.

Overseas transfers

If the candidates are located overseas, client information will be passed on to the overseas candidate with permission from the client

Duration of processing

Unless the client consents to their information remaining on our database, personal data will continue to be processed for the duration of the replacement period, and 3 years following a lack of active engagement

Is the provision of this personal data a statutory or contractual requirement, or a requirement necessary to enter into a contract?

If so, is the data subject obliged to provide the personal data in question?

What are the possible consequences of failure to provide such data?

You are not obliged to provide the personal data in question. However, if you do not provide the personal data, we may be unable to match your details up with potential candidates.

Is there any automated decision-making done using the personal data (including profiling)?

No.

Plans for further processing

Unless given permission by the candidate, no further processing will be carried out following the end of the replacement period.

  1. Information Security

6.1 We will use technical and organisational measures to safeguard your data.

6.1a Access to the account where your data is stored is password controlled. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

6.1b We store your data on secure servers

6.2 We have implemented appropriate technical and organisational measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your data, please let us know immediately by contacting us via this email address: info@gillespiemanners.com.

 

  1. Our Use of Cookies

7.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

  • By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third Party Cookies are used on Our Site to allow our website to present you with customised Web pages and to also track which pages you may have visited. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
  • All Cookies used by and on Our Site are used in accordance with current Cookie Law.
  • Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
  • Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These ‘Essential Cookies’ are shown below in section 5.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 6.7, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
  • The following Cookies may be placed on your computer or device:

Essential Cookies. Essential cookies enable you to navigate the Site and to use its services and features. Without these strictly necessary cookies, the Site will not perform as smoothly for you as we would like it to and we may not be able to provide the Site or certain services or features.

Preference Cookies. Preference cookies collect information about your choices and preferences and allow us to remember language or other local settings and customize the Site accordingly. These cookies allow us to provide a more personalized experience.

Social Media Cookies. Social media cookies collect information about social media usage. We use social media cookies to help us integrate social media sharing tools into our Site and to measure the effectiveness of these sharing tools.

Analytics Cookies. Analytics cookies collect information about your use of the Site and enable us to improve the way it works. For example, analytics cookies show us which are the most frequently visited pages on the Site, help us record any difficulties you have with the Site, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on the Site, rather than the usage of a single person. We use the information in aggregate form to analyze Site traffic and perform statistical analyses of the collective characteristics and behavior of our visitors by measuring demographics and interests regarding specific areas of the Site, but we do not examine this information for individually identifying information.

Advertising Cookies. Advertising cookies are set to display targeted promotions or advertisements based upon your interests on the Site or to manage our advertising. These cookies collect information about your activities on this Site and other sites to provide you with targeted advertising.

Pixel tags. Pixel tags (also known as web beacons and clear GIFs) are used to, among other things, track the actions of users of the Site, measure the success of our marketing campaigns, and compile statistics about usage of the Site and response rates.

Adobe Flash. We use Flash Local Shared Objects (“Flash LSOs”) and other technologies to, among other things, collect and store information about your use of the Site. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your consent, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Site.

Browser or Device Information. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Site you are using. We use this information to ensure that the Site functions properly.

Google Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This information allows us to measure Site performance and improve our Services. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Physical Location. We collect the physical location of your device by, for example, using satellite, cell phone tower, or WiFi signals. We use your device’s physical location to provide you with personalized location-based services and content. We also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you can allow or deny such uses and sharing of your device’s location, but if you do, we and our marketing partners may not be able to provide you with the applicable personalized services and content.

Device Fingerprinting. To offer you content that we believe may interest you based on your activity on the Site, and for fraud prevention and authentication purposes, we may also use other technologies that are similar to cookies. For example, we may gather device attributes and combine information collected by most browsers or automatically through your device to create a unique ID that identifies your browser or device to us with reasonable certainty. In this context we may collect, use, and combine certain information about your device, including, but not limited to: Last visit, first visit and number of visits; IP address (external and internal), geolocation (latitude/longitude based on IP address); device user-agent (browser type, version), device operating system, keywords used if coming from search engine, pages visited. 

  • In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
  • You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
  • It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 

 

 

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