Privacy Policy

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.

We will disclose your personal information to third parties:

To whom we may choose to sell, transfer, or merge parts of our business or 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.

Suppose we are under a duty to disclose or share your personal data to comply with any legal obligation, to enforce or apply our terms and conditions of service and other agreements, or to protect the rights, property, or safety of Circle Eight Recruitment, our Candidates, Clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where a third party processes your personal data – the lawful basis for the third-party processing will include the following:

Their legitimate business interests in processing your personal data, in most cases, to fulfil their internal resourcing needs.

Satisfaction with their contractual obligations to us as our data processor.
For a contract in place or contemplation.

To fulfil their legal obligations.

We require all third parties to respect the security of personal data and treat it according to the law. We do not allow third-party service providers with whom we may work to use your personal data for their purposes. We only permit them to process your personal data for specified purposes and by our instructions.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries deemed to provide adequate protection for personal data by the European Commission.

We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please get in touch with us at rafa@circleeightrecruitment.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and where you are happy for us to do so.  We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.



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 requirements.

We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our primary Customer Relationship Manager (CRM) system. We may pseudonymise pieces of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data into our database unless requested. For your information, Pseudonymised Data is created by identifying fields within a database and replacing them with artificial identifiers or pseudonyms.



Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by email to rafa@circleeightrecruitment.com

Data Security

It is essential to be aware that, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.

Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.  All information you provide to us is stored on our secure servers in the UK. 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 are subject to a duty of confidentiality.

We have established procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.

Your legal rights

Under the GDPR, you have the right to:

Request access to your personal information, which involves confirming with us whether we are processing your personal data and, if we are, request access to that personal data, including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to consider the interests of others, though, so this is not an absolute right.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

Request the erasure of your personal information. 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 information where you have exercised your right to object to processing (see below).

Object to processing your personal information where we rely 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. You also have the right to object where we are processing your personal information for direct marketing purposes.  To stop receiving marketing communications from us or change your preferences, please get in touch with us at rafa@circleeightrecruitment.com

Request the transfer of your personal information to another party in specific formats, if practicable.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

Withdraw consent to the processing at any time. We rely on support 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 provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Make a complaint to a supervisory body in the United Kingdom, the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

If you wish to exercise any of the rights set out above, please get in touch with the DPR at rafa@circleeightrecuitment.com

You will not have to pay a fee to access your data (or exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may 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 about your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Changes to our Privacy Policy

This Privacy Policy is effective as of 2 February 2021.  Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently for any updates or changes to our Privacy Policy.

Contact 

Questions and queries regarding this Privacy Policy are welcomed and should be addressed to

Rafa Hussain
Circle Eight Recruitment Limited

rafa@circleeightrecruitment.com 
+44 (0)20 71128150

You have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate the chance to deal with your concerns before you approach the ICO, so we encourage you to contact us in the first instance.

Cookies

Our website uses cookies to differentiate you from other users of our website. This helps us to provide you with sound knowledge when you browse our website and allows us to improve our site. For detailed information on the cookies, we use and the purposes for which we use them, see our Cookie Policy.

Disclosure of your information inside and outside of the EEA
We will share your personal information with the following:

Any member of our group in the EEA and outside of the EEA.

Selected third parties including:

  • clients to introduce candidates to them.
  • candidates to arrange interviews and engagements.
  • clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter with them or you.
  • subcontractors, including email marketing specialists, event organisers, payment, and other financial service providers.
  • analytics and search engine providers that assist us in improving and optimising our site.
  • 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.

We will disclose your personal information to third parties:

  • If we sell or buy any business or assets, we will disclose your personal data to the prospective seller or buyer.
  • If a third party acquires Circle Eight Recruitment or substantially all its assets, personal data about its customers will be one of the transferred assets.

Suppose we are under a duty to disclose or share your personal data to comply with any legal obligation, to enforce or apply our Terms of Use (create hyperlink) and other agreements, or to protect the rights, property, or safety of Compliance Professionals, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The lawful basis for the third-party processing will include the following:

  • Their lawful business interests in processing your personal data, in most cases, to fulfil their internal resourcing needs.
  • satisfaction with their contractual obligations to us as our data processor.
  • for the purpose of a contract in place or contemplation.
    to fulfil their legal obligations.

Storing and processing your personal data  

The data we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (” EEA”). It may be transferred to third parties outside the EEA for our recruitment services. It may/will also be processed by staff operating outside the EEA who work for one of our suppliers or us. This includes staff engaged in, among other things, our recruitment services and support services. By submitting your personal data, you agree to this transfer, storing or processing. Compliance Professionals will take all steps reasonably necessary to ensure that your data is treated securely and under this privacy notice.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet could be more secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.  Accordingly, we have a data retention policy and run data routines to remove data that we no longer have a legitimate business interest in maintaining.

We do the following to try to ensure our data is accurate:

  • Our website enables you to manage your data and to review whether the details we hold about you are accurate.
  • Before making an introduction, we check that we have accurate information about you.
  • We keep in contact with you so you can inform us of changes to your personal data.

We segregate our data to keep different data types for different periods. The criteria we use to determine whether we should retain your personal data include the following:

  • the nature of the personal data.
  • its perceived accuracy.
  • our legal obligations.
  • whether an interview or placement has been arranged; and
    our recruitment expertise and knowledge of the industry by country, sector, and job role.

We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our primary Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we only re-enter your personal data into our database if requested.

For your information, Pseudonymised Data is created by identifying fields within a database and replacing them with artificial identifiers or pseudonyms.

 

Connect

Phone

020-71128150