Cameron Pink (referred to as ‘the Company’ or ‘Cameron Pink’ or ‘We’ or ‘Our’) is a recruitment business which provides work finding services to clients and job seekers. We process personal data (including sensitive personal data) so that it can provide these services – as such, we are a data controller.
The Company might receive your data via a job application or via our website, or we may collect them from job boards or social media. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services or information relating to roles relevant to you we will only use your personal data in accordance with the terms below –
COLLECTING AND USING PERSONAL DATA
1) Purpose of processing and legal basis
The Company will collect personal data (sometimes including sensitive personal data) and will process it for the purposes of providing you with work-finding services (e.g., contacting you in regards to a job opportunity, updating our database). Sometimes we might be required to use your data for the purpose of investigating or detecting crime and also to comply with UK law.
The legal basis we rely upon to offer these services to you are: A legitimate business interest
2) Legitimate interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests are as follows:
•Managing our database and keeping work-seeker records up to date
•Providing work-finding services to the individual, including sending their information to our clients where they have demonstrated an interest in doing that particular type of work but not expressly consented to us passing on their CV.
3) Recipients of data
To the extent necessary or appropriate and without notifying you, Cameron Pink may disclose your Personal Information to external third parties including:
•To companies and individuals we employ to perform business functions and services on our behalf. Examples of service providers include: providing payroll services to enable us to pay our employees and temporary workers who work on client premises; background screening and verification services; data storage facilities including in the Cloud; hosting our Web servers; analysing data and producing statistics and legal, accounting, audit and other professional services.
•To government agencies including: HM Revenue & Customs; UK Border Agency; Home Office; Police and other law enforcement agencies; regulatory and supervisory authorities (such as the UK Information Commissioner); credit reference agencies; the Disclosure and Barring Service; and third parties performing sanctions and terrorism checks.
•To comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to: (a) comply with the law requiring such disclosure; (b) protect the rights or property of Cameron Pink; (c) prevent a crime, protect national security or for fraud detection or prevention; or (d) protect the personal safety of individuals using our website or members of the public.
•To IT consultants carrying out testing and development work on our IT systems, service providers who we may appoint as data processors and to other service providers.
•We will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
Where applicable, we will impose appropriate contractual, security, confidentiality and other obligations on to
3rd party service providers and processors we have appointed, based on the nature of the services they provide to us. We will only permit them to process your Personal Information in accordance with the law and our instructions. We do not allow them to use your Personal information for their own purposes and when our relationship ends we will ensure your Personal Information is securely returned or destroyed.
Some of these third parties are also controllers responsible for processing your Personal Information for their purposes, for example, HM Revenue & Customs is a controller for tax purposes. We may not be able to impose obligations or restrictions on these controllers in connection with how they process your Personal Information.
KEEPING YOUR DATA SECURE
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to do so.
The Company will retain your personal data for as long as is necessary for the purpose we collect it. The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from record creation or when we last provided you with work-finding services. At times HMRC and associated tax legislation will require us to keep your data longer. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data.
You have the following data protection rights:
•The right to be informed about the personal data the Company processes on you;
•The right of access to the personal data the Company processes on you;
•The right to rectification of your personal data;
•The right to erasure of your personal data in certain circumstances;
•The right to restrict processing of your personal data;
•The right to data portability in certain circumstances;
•The right to object to the processing of your personal data that was based on a public or legitimate interest;
•The right not to be subjected to automated decision making and profiling; and
•The right to withdraw consent at any time.
There may be circumstances where the Company will still need to process your data for legal or official reasons mentioned previously. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.
If you want to restrict the data we process for you or believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
COMPLAINTS OR QUERIES
Please contact: James Emanuel, Cameron Pink Limited, 207 Regent Street, W1B 3HH.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk if you believe that your data protection rights have not been adhered to.