Privacy Policy
Privacy Policy (last updated 09/01/2023)
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 |
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. |
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 |
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. |
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