Who are we?
Newcomen Partners Ltd operate as an employment agency and an employment business, providing permanent, interim and contract recruitment solutions to finance professionals in the UK and internationally.
What does this Policy cover?
We at Newcomen Partners Ltd take your personal data seriously. This policy:
* sets out the types of personal data that we collect about you
* explains how and why we collect and use your personal data
* explains how long we keep your personal data for
* explains when, why and with who we will share your personal data;
* sets out the legal basis we have for using your personal data;
* explains the effect of refusing to provide the personal data requested;
* explains the different rights and choices you have when it comes to your personal data; and
* explains how we may contact you and how you can contact us.
What personal data do we collect about you?
We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the different stages of recruitment. This information includes but is not limited to CV’s, identification documents, educational records, work history, employment and references, contact information, remuneration details.
In order to comply with the Conduct of Employment Agencies Regulations we are also required to process a copy of your passport.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
* Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages.
* From an agent/third party acting on your behalf. e.g. Contractors Limited Company.
* Through publicly available sources. We use the following public sources:
* Social Media sites such as Linkedin, ZoomInfo
* Job Boards
* CV Libraries
* By Reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
How do we use your personal data?
We use your personal data to match your skills, experience and education with a potential employer.
We collect data as above in order to assess which opportunities within our network will be best suited to you. Then, having briefed you on those opportunities and gained your permission, we will submit a CV or profile to the clients concerned.
How long do we keep your personal data for?
We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
*** our contractual obligations and rights in relation to the information involved;
*** legal obligation(s) under applicable law to retain data for a certain period of time;
*** statute of limitations under applicable law(s);
*** (potential) disputes;
*** if you have made a request to have your information deleted; and
*** guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
Who do we share your personal data with?
We share candidate personal data with the clients and contacts within our network with whom we have opportunities that will be suitable for you. This data is shared once we have permission from you as the candidate.
We share client contact personal data with candidates who are potentially suitable for opportunities within that client.
What legal basis do we have for using your information?
For prospective candidates, contractors, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.
If you are interviewed and submitted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
For clients, we may also rely on our processing being necessary to perform a contract for you, for example in helping you secure finance professionals.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we may not be able deliver to you the services you would expect from us or indeed be able to represent you.
Do we make automated decisions concerning you?
No, we do not carry out automated profiling.
Do we transfer your data outside the EEA?
To better match your employee profile with current opportunities, and with your express permission, we may transfer your personal data to clients and partners in countries outside the EEA. These countries privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal data. To find out more about how we safeguard your information as related to transfers contact us on firstname.lastname@example.org
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
Rights; What does this mean?
1. The right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
3. The right to rectification You are entitled to have your information corrected if it’s inaccurate or incomplete.
4. The right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
7. The right to object to processing You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
8. The right to lodge a complaint You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
9. The right to withdraw consent If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for: * baseless or excessive/repeated requests, or * further copies of the same information. Alternatively, we may be entitled to refuse to act on the request. Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us here.
What Cookie types do we use?
Our Cookies are either first party or third party. Whether a Cookie is ‘first’ or ‘third’ party refers to the website or domain placing the Cookie. First Party Cookies are placed directly by us, while other parties we may do business with set Third Party Cookies. These third parties collect data directly from your web browser and the processing of this data is subject to their own privacy policies.
Cookies are either:
Session Cookies – which allow websites to link your actions during a browser session. We may use these for a variety of purposes such as remembering what you clicked on, on the previous page visited. These session Cookies expire after a browser session so would not be stored longer term; or
Persistent Cookies – which are stored on your device in between browser sessions and allow your preferences or actions across a site (or in some cases across different websites) to be remembered. These Cookies do not expire once the browsing session closes and remain on your device until an expiration date set by the source of the Cookie.
What are the categories of the Cookies we use?
Essential Cookies: These Cookies are essential to make our website work correctly, they enable you to move around our website and use our features. These Cookies are necessary for the provision of our services and if you do not want us to collect such information, you must cease using our website immediately.
Performance Cookies: These Cookies help us understand how you interact with our website, by providing information about the areas visited, the time spent on the website, and any issues encountered, such as error messages. This helps us improve the performance of our website.
Functionality Cookies: These Cookies allow our website to remember if you have previously visited our site or the choices you make (such as your user name, language, region or preferences) to provide a more personalised online experience.
Targeting/Advertising Cookies: These Cookies are used to deliver content that is more relevant to you and your interests. They may be used to deliver targeted advertising or to limit the number of times you see an advertisement.
How do you manage Cookies?
Most internet browsers are initially set up to automatically accept Cookies. You can change the settings to manage Cookies being sent to your device.