WORK SEEKER / CONTRACTOR, CLIENT AND SUPPLIER PRIVACY NOTICE
(The most up -to-date version of this privacy notice can be found on our website)
1. Scope
Our Privacy Notice describes the ways we collect your personal information and governs how we will deal with it. We aim to ensure that any personal information we obtain and use will always be held, used and transmitted in compliance with the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together referred to as the ‘Data Protection Laws’)
The website containing this Privacy Notice may contain links to third parties’ websites. GSS assumes no responsibility for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those websites before either agreeing to their terms or using those websites.
This Privacy Notice applies with immediate effect to all Data collected from Data Subjects, (including work seekers, contractors, clients, suppliers or interested 3rd parties) either through the GSS Website or any other means.
GSS may occasionally amend this Privacy Notice to reflect regulatory requirements and changes in our information collection and disclosure practices. Any new Privacy Notice will automatically be effective when it is published on the website. We advise you to print a copy for your records.
2. Responsibilities
The RTC Group Data Protection Representative, acting on behalf of GSS, has overall responsibility for ensuring that this notice is applicable, compliant and in accordance with the RTC Group Data Protection Policy. The GSS Data Protection Representative (DPR) is responsible for ensuring that the contents of the Notice are implemented on behalf of the RTC Group, where applicable. GSS is part of the RTC Group of companies.
All Employees / Staff of GSS who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and where applicable, their consent to the processing of their data is secured.
3. Privacy Notice
3.1 Who are we?
GSS are part of the RTC Group.
With specialist focus on supporting and delivering projects in “remote and hostile” locations, GSS works with companies based in the UK, Middle East, USA and Canada, who are providing support to commercial enterprises and organisations such as NATO and other defence agencies.
As part of our commitment to protecting our candidates, contractors, clients, suppliers and 3rd parties data, we have implemented a stringent Information Security Management system to protect both the security and integrity of the data we process.
As part of our commitment to managing individual’s rights, we have appointed a Data Protection Representative.
The GSS Data Protection Representative can be contacted directly here: DPR@ata-gss.com
3.2 What information do we collect?
| Personal data type | Source | Legal Basis |
|---|---|---|
| Contact name, social media profile (In the public domain), job title, previous experience) | Social media profiles/3rd party job boards | Legitimate interest/contract |
| Contact Information, such as name, address and telephone number | Your submitted CV or details via our website / 3rd Party Job Boards/telephone business development sources, referrals, supplier details | Legitimate interest/contract |
| Online contact information, such as your email address | Social media profiles/Your submitted CV or details via our website / 3rd Party job boards business development sources, referrals, supplier details | Legitimate interest/contract |
| A copy of your CV | Social media profiles/your submitted CV or details via our website / 3rd party job boards | Legitimate interest/contract |
| Other personal information such as your preferred employment requirements, qualifications/ training certificates, driving license / bank details / next of kin details | Your submitted CV/details via our website or personal interaction | Legitimate interest/contract |
| Personal health data that may be required from an occupational health screening perspective to confirm suitability for a role. | Personal interaction | Legitimate interest/contract/consent |
| Relevant travel documents e.g. passports or visa’s | Personal interaction/submitted document(s) | Legitimate interest/contract |
| Police Clearance Certificate (PCC) / Criminal Record Checks | Personal interaction | Legitimate interest/contract |
| Navigation and click-stream data, the time of accessing the website, duration of your visit, pages and job vacancies you viewed or searched for | Our website | Legitimate interest/contract |
| Information from cookies or web beacons | Our website | Legitimate interest/contract |
| Your requested restrictions on our data processing such as preferred employers | Personal interaction/your submitted CV or details via our website | Legitimate interest/contract |
| Your Subject Access Requests | Personal interaction/email/telephone conversation or in writing | Legitimate interest/contract |
It may be necessary for us to collect data, which under Data Protection Law os classified as Special Categories of Personal Data
- Racial
- Ethnic origin
- Political opinions
- Religious beliefs
- Philosophical beliefs
- Trade union membership
- Genetic data
- Biometric data
- Health data
- Data concerning a natural person’s sex life
- Sexual orientation
- Other
It is anticipated that Special categories of personal data required from a work seeker / contractor will be for the purposes of assessing suitability for assignment in remote and hostile locations (i.e. health and criminal background records), and ongoing monitoring of such in accordance with your contract. Your personal data may also be used in the normal due process of applying for visa/work permits and other necessary documentation as may be required to undertake work in a particular global location in accordance with local labour laws.
Consent will always be sought prior to this data being stored and processed
3.3 How we collect your information if you are a work seeker or prospective work seeker
GSS obtains information from you in three ways:
A. Submitting your details
If you wish to apply for a vacancy online or submit your details to one of our agents, we may ask you for your contact information and/or CV details and/or job requirements/ personal details.
B. Automatic collection
Like most websites, our website uses cookies and web beacons to enhance your visitor experience. Please visit our Website Privacy Notice for further details.
C. Information from third parties
GSS may also obtain information about you directly from third parties, such as 3rd party job boards, 3rd Party Agents, Social Media sites and CV websites. GSS will use this information to update our database records. If we have found your details on a social media website, they will only be retained during the process of establishing your consent for us to contact you. If you do not require our assistance in the job market, you may ask for your details to be removed from our systems.
Independent of how we collect your data, we will always ensure that you have access to the relevant Privacy Notice.
If we have gathered your information from a 3rd Party we will always seek authorisation from you to store and process your data.
Additional Terms and Conditions associated with using our website, including our use of cookies, can be found in our website privacy notice.
If you want to disable cookies you need to change your website browser settings to reject cookies.
What will we do with your information if you are a work seeker or prospective work seeker?
We will process and store your information for any or all of the following purposes;
Whilst engaged by us
The principal purposes for which we collect and store your personal information whilst you are on engagement is to meet our contractual obligations identified within your contract.
During the provision of job seeking activities
The principal purposes for which we collect and store your personal information are to process your job application, respond to your enquiries, get in touch with you about other possible job opportunities and generally maintain the information you hold with us, together with improving our website. You will be given the opportunity to restrict this use at any time.
To assist with marketing of GSS services
In order to ensure that we provide you with the best possible work opportunity and our client with the best possible candidate, we may also use your data for Marketing purposes.
Occasionally, GSS may contact you by telephone for the purposes of market research, marketing our services (and for telemarketing) where you have consented to us doing so. You are under no obligation to participate in the call.
In addition, we may use an IP address to identify you and to gather broad demographic information about you, which may be used to assist GSS in market segmentation activities, to help identify problems with our server and to administer our website.
3.5 What will we do with your information if you are a client / supplier or potential client / supplier
Contractual Obligations
The principal purposes for which we collect and store your personal information are to meet contractual obligations. In order to provide our services in an effective and efficient manner we need to ensure that we have the correct communication channels. This is managed through keeping a record of contact positions, email addresses, telephone numbers and business addresses.
New Business Development
Occasionally, GSS may contact you by telephone or email to inform you of our services and capabilities with the intention of developing new business.
In addition, we may use an IP address to identify you and to gather broad demographic information about you, which may be used to assist GSS in market segmentation activities.
If you do not object to receiving marketing material at the time the information was collected from you, but subsequently change your mind and no longer wish to receive this information, you can opt out.
3.6 Sharing with 3rd Parties
GSS will not sell your personal information to third parties. However, on occasions it is necessary for us to share personal information with third parties as described below for the purposes referred to above.
| 3rd Party | Data and Purpose |
|---|---|
| RTC Group | GSS is part of the RTC Group Plc family of companies. We may share your information with other group companies to facilitate our commitment to find you the best possible work opportunities and ensure compliance with our processes. |
| Website analytics providers | GSS collates statistics about site traffic. This information is collected through third parties to assist us in improving the services we provide to you. We also use demographic information to tailor the website to the interests of our work seekers and clients, which we share with third parties, again on an aggregate basis only so that they can build up a better picture of our customer base and general consumer trends. |
| Recruitment and Communications Software | GSS may require to store or process your data with third parties as is necessary to process your application. |
| Legal entities | GSS may disclose your personal information if necessary to comply with regulations or law or to assist with law enforcement, to enforce the terms under which you are contracted with GSS or to protect our or other third parties property and other rights. |
| 3rd Party Recruiter/job board | You may have accessed our website via a hyperlink from another job board. Your personal details including behavioral patterns, may be shared between GSS and that 3rd party. |
| Accounting and Business Development Software | We may retain contact details of existing / potential clients / suppliers on our accounting software and our Client Relationship Management (CRM) software. |
| Successor | In the event that GSS is sold, or some of its assets transferred to a third party, your personal information, as a valuable asset of the company, may also be transferred. However, use of your personal information will remain subject to the Privacy Notice. Similarly, your personal information may be passed on to a successor in interest in the event of a liquidation or administration of GSS. |
Where possible all data processors will be within the EEA. If it is a requirement to transfer data outside of the EEA, this will be in accordance with 3.8 Transferring Data outside of the EAA.
3.7 Transferring outside of the European Economic Area (EAA)
GSS will only transfer data outside of the EAA if necessary.
GSS do not currently transfer your Data outside of the European Economic Area without your consent. However, should there be a general business requirement to do so, we will record the details in the table below and re-issue this Privacy Notice.
Should we be required to pass your information onto a country outside of the European Economic Area on an individual basis, we will seek your consent to do so. This is usually a requirement when applying for a post overseas.
3.8 Consent and Permissions
For the purposes of this Privacy Notice, GSS refer to Consents and Permissions.
The difference between consent and permission can be seen below;
Consent; requires a physical record from yourself.
Permission; can be granted by you and recorded by an GSS representative.
By allowing GSS to act on your behalf as a recruitment business and/or a recruitment agency, you are giving us permission to do so in accordance with this Privacy Notice.
By submitting your CV, applying for a specific role, or by providing your details, you are giving us permission to retain your details in accordance with this Privacy Notice.
If we have been provided with your details via a 3rd party, we will seek your permission prior to starting the recruitment process. Should this permission not be granted, upon your request, we shall remove your details from our system.
GSS will seek formal consent if data is to be used for the following activities;
- Processing of EU GDPR defined Special Categories of Personal Data.
- Adding of your contact details to a marketing list that is different from the uses stated in section 3.5 and 3.6 of this Privacy Notice.
- Sharing your information with a processor in a country not contained within the EEA or the US.
Where we are asking you for Special Categories of Personal Data we will always tell you why and how the information will be used.
You may withdraw Consent or Permission at any time by contacting us at optout@ata-gss.com
3.9 Profiling and Automated processing
GSS does not carry out any automated processing activities.
3.10 Retention period
GSS will retain your personal data only for as long as is necessary for the purpose we collect it. Dependent upon the type of data this will be for different periods of time. We will process, store and dispose of Personal Data in line with our Record Retention Process Flow Procedure and the RTC Group Information Security Management Manual.
3.11 How will we contact you?
We will contact you in the following circumstances;
| Circumstance | How | Why |
|---|---|---|
| If you submit your details to our website in response to a particular job advertisement. | Telephone or email in the first instance. | To inform you of the status of your application and to further the conversation. |
| If you submit your details on a speculative basis to our website. | Telephone or email in the first instance. | To further the conversation and to find out more about how we can help you seek work. |
| If we receive a referral | Telephone, email or social media where appropriate. | To find out if you are content to be referred, communicate our Privacy Notice and to confirm permissions if appropriate. |
| If we find your details on LinkedIn and think that you may be suitable for a current opportunity. | Social Media, email and telephone. | To find out if you are content to be referred, communicate our Privacy Notice and to confirm permissions if appropriate. |
| If we receive your CV or contact details through a 3rd Party job board / website | Telephone or email in the first instance. | To find out if you are content to be contacted, to communicate our Privacy Notice and to confirm permissions if appropriate. |
| If we believe that we can legitimately assist you with your recruitment requirements | Telephone or email in the first instance. | To offer our services. |
| If we believe that we have a need for your products or services. | Telephone or email in the first instance | To request information about services or products or to engage in contract negotiations. |
| If we require to contact you for contractual reasons. | Telephone or email in the first instance | To implement a contractual requirement. |
3.12 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be object to the legal effects of automated processing or profiling.
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right to judicial review: in the event that GSS refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.15 below.
3.13 Requesting information on the data we hold
GSS, at your request, can confirm what information we hold about you and how it is processed. This is called a Subject Access Request. If GSS does hold personal data about you, you can request copies of the information we hold from the GSS Data Protection Representative on the contact details at the end of this Notice.
A Subject Access Request form can be obtained from the Data Protection Representative. Whilst you do not need to complete the form to lodge a Subject Access Request, it will make processing easier.
We will need two different forms of identification to show a facial photograph and address, which can be:
- Passport
- Driving licence
- Birth certificate
- Utility bill (from last 3 months)
- Current vehicle registration document
- Bank statement (from last 3 months
Your request should be emailed to the GSS Data Protection Representative at SAR@ata-gss.com
We endeavour to respond to your request within 1 month of confirming its validity. For more complex requests this may be increased by a further 2 months.
3.14 Complaints and Contacts
In the event that you wish to make a complaint about how your personal data is being processed by GSS or how your complaint has been handled, you have the right to lodge a complaint directly with the ICO and our Data Protection Representative.
The details for each of these contacts are:
| Supervisory authority contact details | Data Protection Representative | |
|---|---|---|
| Contact name: | Information Commissioners Office (ICO) | Compliance and Audit Manager |
| Address line 1: | Wycliffe House, | The Derby Conference Centre, |
| Address line 2: | Water Ln, | London Road |
| Address line 3: | Wilmslow | Derby |
| Address line 4: | SK9 5AF | DE24 8UX |
| Email: | Doe | dpr@ata-recruitment.co.uk |
| Telephone: | 0303 123 1113 | 01332 861 862 |
| Online: | https://ico.org.uk/concerns/handling/ |