Privacy Notice
BACKGROUND:
Pure Human Resources Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and their employees, our employees, suppliers, associates and candidates and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Information About Us
Pure Human Resources Limited.
A limited company registered in England under company number 8189859.
Registered address: Tagus House, 9 Ocean Way, Southampton, SO14 3TJ.
Address: Suite 4, Kingfisher House, Rownhams Lane, North Baddesley, Southampton, Hampshire SO52 9LP.
Email address: info@purehumanresources.co.uk
Telephone number: 01794 329470
We are registered with the Information Commissioners Office as a Data Controller. Our registration number is Z3349873
We are Disability Confident Employer and a member of Romsey Chamber of Commerce. All of our HR consultants are members of the CIPD.
- What Does This Notice Cover?
This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
For employees of Pure Human Resources, we have a separate Employee Privacy Notice which is available in the staff handbook.
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
- What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
- What Personal Data Do You Collect?
We will obtain personal data about you when you send us feedback, submit data onto our website or over the phone / email, post material, complete forms, report a problem with the website, contact us for any reason and by any medium, and share information via the website’s social media functions.
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Name;
- Date of birth;
- Gender;
- Address;
- Email address;
- Telephone numbers;
- Current and past employer names;
- Current and past job title;
- Profession;
- Notice period information;
- Remuneration for current and past employment;
- References;
- Dates of availability (including holiday commitments);
- Information about your preferences and interests;
- Offer of employment start date and offer information;
- Employment end dates and reasons for leaving;
- Matters relating to your employment status and disputes;
- Proof of identity;
- Qualification details and training records;
- Driving licence information;
- Eligibility to work in the UK;
- Equal opportunities data;
- Criminal record checks and declarations may be required for unspent convictions;
- Social media profile;
Your personal data may be obtained from the following third party (our clients):
- A client with who we have a contract provision in place to provide an HR, Training or Recruitment service.
- From our membership from Romsey Chamber of Commerce
- Via our social media channels, which includes but is not limited to LinkedIn, Facebook, Twitter, Instagram
- How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. Our lawful basis may be that the data is necessary for our performance of a contract with you, to comply with our legal and regulatory obligations, because you have consented to our use of your personal data or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your application.
- Providing our clients with appropriate support, information, products and services in relation to any contractual obligations, including candidate information that is submitted via CV, offer letter and Teamtailor records as part of the application process.
- Personalising and tailoring our services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email and post (you may unsubscribe or opt-out at any time by clicking on unsubscribe on our emails or emailing info@purehumanresources.co.uk).
- Applications for vacancies (CV’s, application forms and cover letters) will only be used for the purpose of progressing a person’s application for that role, to assess a person’s suitability for that role or to fulfil legal or regulatory requirements as necessary.
- To confirm the identity of those employees and applicants of our clients and their right to work in the United Kingdom.
- To enable us to complete pre-employment checks for either our clients or Pure Human Resources.
- To enable our clients to fulfil any contractual obligation set out in the written statement of employment terms and conditions.
- Personal sensitive data will be subject to additional internal security measures. If such data is requested, you will be given additional information as to why the sensitive data is being requested and how it will be used, often this will be required to provide you with our services.
- To submit our statutory returns.
- Operational reasons, such as improving efficiency, training and quality control.
- Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures
- Ensuring safe working practices, staff administration and assessments.
- We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.
With your permission and/or where permitted by law, we may use your personal data for marketing purposes, which may include contacting you by email or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 11.
- The following automated decision-making method(s) may be used:
- Right to work in the UK, based responses from the applicant.
- Screening questions - these are specific to each role and dependent on selection criteria set by the client company.
- The following automated profiling may take place:
- The use of psychometric tools, for which we are licenced to use. This may be for recruitment, training and development or coaching purposes. These psychometric test and questionnaires will never be used for solely making a decision about a candidate in recruitment but will be combined with other selection methodology. We operate in line with the British Psychological Societies guidance of the use of Psychometric tools in the workplace https://ptc.bps.org.uk/
- The following automated job shortlisting may take place:
- Using Teamtailor, our applicant tracking system. For job vacancies, there may be selection criteria questions added. These will be limited to the minimum criteria for the role advertised (as determined by our client). Where candidates do not meet this minimum criteria or where they are unable to answer the questions, they may be deselected from progressing through to the next stage of the recruitment process.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Record / Documentation Description
Duration of Retention
Job applications
6 months from closure of the recruitment exercise
Job offers
If we provide HR support services to that client then this will be for current employment plus 7 years
Occupational Health reports for client employees
For the duration of client engagement (to fulfil contractual obligation) plus 6 months. This information will be marked as Special Category Data and stored separately from other employee data.
- How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR.
- Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject except for:
- HR systems providers (includes breatheHR and Teamtailor)
- Occupational health services (Adept OH)
- DBS checking providers
- DVLA
- Associates
- Electronic signature software (Signable)
Other third parties we use to help us run our business, e.g. website hosts
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is required by a third party, as described above, we only allow this sharing if we are satisfied that appropriate measures are in place and we
will also take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
We may also need to share some personal information with other parties, such as potential buyers of some / all of our business, or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
- How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
You may also need to provide proof of identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill) to access any personal data we hold on you.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Stephanie Fosh):
Email address: info@purehumanresources.co.uk.
Telephone number: 01794 329470.
Postal Address: Pure Human Resources, Suite 4, Kingfisher House, Rownhams Lane, North Baddesley, Southampton SO52 9LP.
- Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available via our website and terms of business.
February 2023
