Circle Eight Recruitment is committed to protecting and respecting your privacy.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The GDPR aims to harmonise data protection legislation across the European Union, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

Who we are and what we do

We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business).  We collect the personal data of the following types of people to allow us to undertake our business.

• Prospective and placed candidates for permanent, fixed term or temporary roles.
• Prospective and live client contacts.
• Supplier contacts to support our services.
• Employees, consultants, and temporary workers.

We will be sure to collect information about you to carry out our core business and ancillary activities.

This Privacy Policy describes how we collect, use, and process your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a favour from you or if you are visiting our website.

This Privacy Policy applies to the personal data of our:

Clients: our candidates, clients and prospective candidates and clients to whom we provide or market our recruitment services during our business.

Suppliers: partnerships and companies (including sole traders), contractors and consultants who provide services to Circle Eight Recruitment. The Supplier will be responsible for communicating this Privacy Policy to their or its employees.

Candidates: applicants for roles advertised or promoted by us, including permanent, part-time and temporary positions with Clients of Circle Eight Recruitment and people who have supplied a speculative CV to Circle Eight Recruitment, not about a specific job. In this Privacy Policy, the term Candidate includes individual contractors and individuals providing their services via personal services and umbrella companies.

What kind of information do we collect?

Client Data
We collect your personal data (for example, name and contact details) when we receive it directly from you, such as where you contact us proactively (by phone, email, in person) or where you connect with our consultants on business networking sites or through our consultant’s business development activities more generally.

We may seek more information about you from analysing online and offline media, and we may be supplied with information about you by Candidates (for example, when you are named as a referee).

Candidate Data
We may collect some or all the information listed below to enable us to offer you employment opportunities tailored to your circumstances and interests. This may include: your name,  contact numbers, email addresses, curriculum vitae, photograph, education details, employment history, and links to your professional profiles available in the public domain, e.g. LinkedIn, Twitter, business Facebook or corporate website) immigration status, financial information (where we need it to carry out financial background checks or pay you), social security number and tax-related information, referee details, details about your current remuneration, pensions and benefits arrangements and emergency contact details; in addition, you may choose to share other information with us that you think is relevant.

Where appropriate or necessary (and by legal requirements), we may also collect information related to your health or details of any criminal convictions (where this is required for a role you are applying for). We may ask you to provide diversity information (voluntarily) for the reasons and in the circumstances set out below.

Collecting personal data?
We collect information about Candidates when you register as a Candidate by sending us your CV or by corresponding with our consultants by phone, e-mail or in person.

You may also provide us with your data when you use our website, subscribe to our services, participate in salary and other market surveys, attend our events, participate in discussion boards or other social media functions on our site, apply for jobs with us via a job board which then redirects you to our website and if you report a problem with our website.

Where we obtain your information through LinkedIn or other business networking sites (for example, where you choose to connect with one of our consultants), we will email you a link to this Privacy Policy so that you can review it and decide what information you would like us to provide to you.

We may also receive personal data about you from other sources, such as referees, our clients and from third-party sources, such as LinkedIn and other job board websites, your business card and personal recommendations.  For example, if you ‘like’ our page on Facebook or ‘follow’ us on Twitter, we will receive your personal information from those sites. If you were referred to us through a recruitment process outsourcer (RPO) or other Suppliers – they might share personal information about you.

We also work closely with third parties, including our group companies, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, and professional advisors.  We may receive information about you from them for our recruitment and additional support services.

Supplier Data
We need personal data to ensure our relationship with you runs smoothly, such as contact details of relevant individuals at your organisation so that we can communicate with you and may need bank details to pay you for your services.

Information collected by website users

There is certain information we may automatically collect whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content.

How do we use your personal data, and what is the legal basis for the processing?

We use Candidate data as follows:

We are storing your details (and updating them when necessary) on our database so we can contact you concerning recruitment services.

We are providing you with our recruitment services and facilitating the recruitment process.

Assessing data about you against vacancies which may be suitable for you. Send your information to Clients (with your prior consent) to apply for jobs or assess your employment eligibility.

You can submit your CV, apply online, or subscribe to alerts about jobs we think may interest you.

We are carrying out our obligations arising from any contracts between us.

We are carrying out our obligations arising from any contracts between Circle Eight Recruitment and third parties about your recruitment.

We are facilitating our payroll and invoicing processes (when Circle Eight Recruitment is responsible for paying you)—carrying out market surveys and market reports.

You are verifying the details you have provided using third-party resources (such as psychometric evaluations and regulatory checks).

To request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and necessary concerning the roles you are applying for).

We comply with our legal obligations concerning the detection of crime or the collection of taxes or duties.

Processing your data enables us to send you targeted, relevant marketing materials or other communications that interest you.

Using Client data as follows:

To provide our clients with the very best service possible.

We store your and individual contacts’ data at your organisation and keep records of our conversations, meetings, registered jobs, and placements on our database.

From time to time, we may ask you to undertake a customer satisfaction survey.

Processing your data enables us to send you targeted, relevant marketing materials or other communications that interest you.

We use Supplier data as follows:

To facilitate receipt of services from you, we hold your financial data so that we can pay you for your assistance.
To enable us to send you targeted, relevant marketing materials or other communications that interest you.

Our legal basis for personal processing data is our legitimate business interests, described in more detail below. However, we will also rely on contracts, legal obligations, and consent for specific uses of data.

We will rely on a contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive benefits from you or your organisation.

We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations – including where you are applying for roles or placed in a regulated environment.

We will, in some circumstances, rely on consent for particular uses of your data, and you will be asked for your express consent if legally required.  Examples of when consent may be the lawful basis for processing include permission to introduce a Candidate to a Client and sending third-party marketing communications to you via email.

Concerning marketing – you have the right to opt out of accepting marketing from us at any time by contacting us at rafa@circleeightrecruitment.com. Suppose you have previously engaged with us (for example, submitting a job application or CV or registering for a vacancy to be filled), and we are marketing other recruitment-related services. In that case, we will take your consent as given unless or until you opt-out (this is called soft opt-in consent).

Where we need to collect personal data by law or under the terms of a contract we have with you, and you need 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. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Our Legitimate Business Interests

Our legitimate interests in collecting and retaining your data are described below:

To support our Candidates’ career aspirations and our clients’ resourcing needs, we require a database of Candidate and Client personal data containing historical information as well as current resourcing requirements for a recruitment business and recruitment agency; we introduce Candidates to Clients for permanent employment, temporary worker placements or independent professional contracts.  The exchange of our Candidates’ and Client contacts’ personal data is a fundamental, essential part of this process.

We think that it is reasonable to expect that if you are looking for employment or have posted your professional background and information on a job board or professional networking site which allows the public (including recruiters) to view your information – that you are happy for us to collect and otherwise use your data to offer or provide our recruitment services to you, assess your skills against our bank of vacancies and, with your consent, share that information with prospective employers.

Once an offer of a role is made to a Candidate, your prospective employer may also want to double-check any information you’ve given us (such as the results from psychometric evaluations or confirm your references, qualifications, and criminal record) to the extent that this is appropriate and necessary for the role.

Equal opportunities monitoring

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities.

We may ask you to provide personal data about your ethnic background, gender, disability, age, sexual orientation, religion, or other similar beliefs so that we can use this information anonymously to monitor our compliance with our equal opportunities policy.

We may also disclose this anonymised data to Clients where this is contractually required, or the Client specifically requests such information to enable them to comply with their diversity goals and employment processes.

You will be asked to explicitly tell us that you agree to us collecting and using this information (i.e., opting in).

You have the right to withdraw your consent at any time, and we will cease to carry out the activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case, we will inform you of this condition.

Consent

Should we want or need to rely on consent to lawfully process your data, we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing, you have the right to withdraw your consent to this processing at any time (as set out below).

Establishing or defending legal claims

Sometimes, it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, particular category personal data in connection with exercising or defending legal claims.

This may arise, for example, where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason. That reason is compatible with the original purpose. If you wish to explain how the processing for the new purpose is consistent with the consistent purpose, please get in touch with us at rafa@circleeightrecruitment.com for your personal data for an unrelated purpose notify you. 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.

Automated Decision Making or Profiling

We do not undertake automated decision-making or profiling. We use our computer systems to search and identify personal data per a person’s parameters. A person will always be involved in the decision-making process.

Disclosure of your information inside and outside of the EEA

We may share your personal information within our organisation both in the EEA and outside of the EEA and with selected third parties, including:

Clients to introduce Candidates to them.

Candidates to arrange interviews and engagements with Clients.

Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter with them or you.

Cloud-based storage providers.

Subcontractors including email marketing specialists, event organisers, payment, and other financial service providers.

Credit reference agencies, our insurance broker, compliance partners and other sub-contractors to assess your suitability for a role where this is a condition of us entering a contract with you.