PRIVACY POLICY FOR PLUM PERSONNEL LIMITED
Plum Personnel Ltd is a recruitment business which provides work-finding services to its clients and work seekers. Plum Personnel Ltd is committed to providing a first-class recruitment and employment services whilst protecting the privacy of our candidates, clients and others.
This Privacy Policy explains how we use any personal information we collect about you and applies to the personal data of website users, candidates, clients, suppliers and other people whom we may contact such as reference and emergency contacts and is aligned to the GDPR and PECR privacy principles.
Plum Personnel will always endeavour to manage data safely, securely and responsibly and have worked closely with the Recruitment and Employment Confederation, software providers, IT support to ensure we are GDPR compliant.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Along with our business and internal computer systems, this website is designed to comply with the EU General Data Protection Regulation 2018 (GDPR).
By law we have appointed a representative to oversee the application of our privacy policy.
The Data Controller is Plum Personnel Limited (Company No 4205458) 699 Warwick Road, Solihull, B91 3DA and the Data Protection Officer is Julie Whitehouse. Any concerns over the retention, use or disclosure of your information should be addressed to julie@plum-personnel.com.
Information We Collect and How We Use It
We collect information about you when you register with us for work seeking service, to place an order with us for recruitment services and products or provide us with services.
Plum Personnel Ltd will retain and process data in pursuit of its legitimate interest in providing services to employers and work-seekers and will hold data as part of the contractual and legal obligations Plum Personnel Ltd has as a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Business Regulations 2003.
We may also release personal information to regulatory or law enforcement agencies if they require us to do so.
We may also seek your consent to collect, hold, use and disclose your personal information for any other purpose not listed above, but will only continue to do so if your permission is given and from which you understand you can withdraw permission.
If we are holding historic data that no longer is of use or has any significance it will be erased unless you have given consent, or there is some kind of legal obligation, to retain it.
Please be assured all information will be stored securely and will only be held as long as we have a legitimate interest in holding it.
Any data is held subject to relevant privacy laws. We will not sell your data to any third parties.
Your rights under the General Data Protection Regulations relate to the processing of your data and are as follows –
Work Seekers
In order to provide the best possible work seeking and employment opportunities we need to retain and process certain information about you.
Plum Personnel Ltd must process personal data (including sensitive personal data) so that it can provide work seeking services effectively – in doing so, Plum Personnel Ltd acts as a data controller.
You may give your personal details to Plum Personnel Ltd directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. Plum Personnel Ltd must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.
Collection and use of personal data
Purpose of processing and legal basis
Plum Personnel Ltd will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. We recognise that the legal basis we rely on for processing your personal data may change dependant on the type of work finding services you seek from us whether it be for searching for permanent employment or offering you various temporary or contract opportunities or both and that different types of data may be processed under differing legal basis. The legal basis we rely upon to offer these services to you are:
Legitimate interest
Consent
Legal obligation
Contractual Requirement
Legitimate interest
Where Plum Personnel Ltd has relied on a legitimate interest to process your personal data our legitimate interests are as follows:
Where you have contacted us to provide you with work finding services, we will process your personal details (name, address, telephone numbers and email addresses) so that we can contact you about any temporary and permanent opportunities that may be of interest to you based on your skills and experience and any other relevant information you have freely provided to us in order to assist us in matching you to the most suitable positions.
We will retain your CV and any additional documentation you provide to us (which might include evidence of qualifications and or evidence of work to demonstrate your level of skill/experience) to help us match you to suitable vacancies.
Please do not provide us with any information you do not wish us to hold or process.In order to help us ensure your suitability for positions we will also be required to take up references – you will therefore need to provide us with contact details of referees or evidence of a reference that we can verify.
You will need to obtain their permission before we can contact them.Plum Personnel Ltd have identified, due to our local geographical presence and relationships we build with our candidates and clients, that many candidates are registered with us for a number of years moving from job to job as they progress though their career. We are passionate about building relationships and as such your career history and data we hold on you about how we have assisted you during the period in which we provide you with work finding services will grow and will include the following:
Companies and vacancies that we have submitted your CV and details to
Details of any interviews you have undertaken that have been arranged by us
Details of any placements that you have undertaken through us or provided by us
It is important for us to retain such personal data relating to your activity, work and career so that we can better provide our services to you.
Your personal and sensitive personal data will be inputted into our CRM database to enable us to manage the data in a secure and safe manner as well as utilising the facilities within the database to help provide you with work finding services.
Hard copies of applications forms, ID and other documentation that you complete, sign or provide us with will be stored securely with restricted access and at the appropriate time will be treated as confidential waste and securely shredded and disposed of.
Please see our Data Retention Policy for details on how long we will store your data.
We only ask for relevant and legitimate data and information that will genuinely help us to help you. This may include but is not limited to, your name, date of birth, contact details, education details, proof of the Right to Work in the UK, employment history, emergency contacts, immigration status or financial information (where we need to carry out financial background checks).
On occasions we may also collect other sensitive personal information related to your health or details of criminal convictions. You may either provide us with your CV directly, or via our website or we may receive your CV through a job board to which you have subscribed.
We also use third parties to source information which may include (but not limited to) -
We do not process any personal data of a work seeker without having gained either the permission or informing them. It is always a person who looks at your CV, not a machine, which means no automated decision making takes place.
Data Retention
We generally retain data on candidates for a period of one year from our most recent meaningful contact in providing work seeking services. This is defined as either you or we initiate a contact and getting a response from the other party. It does not include unanswered mails, job alerts or unreturned voicemail messages - unless you request otherwise.
This period is extended to six years from the end of a fixed term or temporary placement as required by HMRC or from the start date of your employment with our client for a permanent placement.
We will retain your personal data only for as long as is necessary and in line with our Data Retention Policy. Different laws require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from
(a) the date of their creation or
(b) after the date on which we last provide you with work-finding services.
Where we have provided you with temporary employment, we must also keep your payroll records, holiday pay, sick pay and pension auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Where we have obtained your consent to process your personal and or sensitive personal data (sensitive data being; disability) we will do so in line with our retention policy. Upon expiry of that period we will seek further consent from you.
Where consent is not granted Plum Personnel Ltd will cease to process your personal data/and sensitive personal data.
Consent
Where we have obtained your data indirectly (ie via a job board, CV database or LinkedIn), in order for us to process your data so that we may offer you work finding services you must give us explicit consent to do so, as well as consent to us holding your data on our CRM system so that we can provide you with these services.
Email & SMS Marketing – so that we can do our best to assist you in finding employment we would like to keep in contact with you to promote additional work finding services we feel are relevant. These might include; job search advice, hints and tips, relevant blogs and offers including ‘refer a friend’.
We need your consent to send this information to you. If you chose not to give us your consent, we can only contact you about relevant job opportunities – but we will not be able to share with you any other information that may assist you in your job search.
To give us explicit consent – you will complete and sign our Registration Form for work finding services which will include your explicit consent to your personal data being retained and processed for work finding services.
Your data will be retained as long as is required by law and no longer than 12-months following the last date Plum Personnel has provided work finding services.
You have the right to –
Medical Conditions/Disabilities
Where you inform us of a disability or medical condition (this is classed as ‘sensitive personal data’) - we can only process this data if you give us explicit consent to do so.
Where you declare medical conditions or a disability to us we may also rely on legal obligation to process this data to ensure we carry out and risk assessment and duty of care in the interests of your safety and legal obligation to make reasonable adjustments.
Nationality
To help us monitor the effectiveness of our Equality & Diversity Policy, Plum Personnel Ltd record your nationality on our database and we need your consent to do so. We can only process this data if you give us explicit consent to do so. In addition you have the option of completing an anonymous Equality Monitoring Form to assist us in ensuring we are maintaining our diversity pledge. Nothing on this form can identify you as an individual.
Legal Obligation
Plum Personnel Ltd have a legal obligation under the Conduct of Employment Agencies and Employment Businesses Regulations 2003 to verify your ID and Right to Work which will require you to show us relevant documentation including a Passport, Driving Licence, Birth Certificate or other formal documentation to confirm your employment status. We will retain copies of this documentation as required by law.
Where we provide you with temporary employment we also have a legal obligation to keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Contractual Obligation
Plum Personnel Ltd have an obligation under the Conduct of Employment Agencies and Employment Businesses Regulations 2003 to provide Terms and Conditions to you confirming the nature of the work finding services and the details of these terms which help us process your data and provide you with those services.
Recipient/s of data
Plum Personnel Ltd will process your personal data and/or sensitive personal data with the following recipients:
In order for us to provide work finding services to you and for our clients to consider you for vacancies they have asked us to fill, it will be necessary for us to forward your CV to these individuals.
We will endeavour to ensure that that those individuals who receive your data process it in accordance with the Terms we have agreed with them and will not process or retain this data for any other purpose.
Statutory/contractual requirement
In certain circumstances your personal data is required by law and/or a contractual requirement (eg our client may require this personal data), and/or a requirement necessary to enter into a contract, for example:
Where a client requires us to submit your data via an online portal in order for them to manage the recruitment process or temporary workers assigned to them
We may be unable to offer you a placement with the client if we cannot meet their requirements by submitting relevant personal data;
Your placement may be terminated if you fail to provide the required personal data within any given timeframe.
We will only share relevant personal data with clients only when it is required by law or in order for us to perform a particular contractual obligation with a particular client.
WE WILL NEVER SHARE YOUR DETAILS WITH THIRD PARTY - ONLY AS PART OF US PROVIDING WORK FINDING SERVICES TO YOU
Customers/Clients/Employers
We need to collect and use information about your organisation or individuals at your organisation in the course of providing recruitment services, products and to fulfil our contractual and legal obligations.
We will let you know of relevant and useful information such as up-to-date employee and job market reports, advise you of news and industry updates, events, promotions and other relevant and meaningful information.
If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes.
Where we do so, you will be able to subscribe (opt-in) or to unsubscribe (opt out) from such communications.
Suppliers
To make sure that our relationship runs smoothly we will collect details for our contacts within your organisation, such as names, telephone numbers and email addresses and if part of our contractual arrangements, you bank details, so that we can pay you.
Associated individuals and Trusted Third Parties
In order to provide recruitment services, we may require some basic background information from individuals so that we can get in touch with a third party either for a reference or because they have been listed as an emergency contact.
We may share data with trusted third parties where we have retained them to provide services such as
We may disclose your personal information to third parties where you have submitted such information in response to job vacancies once you have given us permission.we are under a duty to disclose or share your personal data in order to comply with any legal or contractual obligation for example auditing
Website users
A limited amount of data from our website is collected to help us manage the services we provide.
This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular.
Cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.
We only use Session Cookies to aid your navigation and use of this website while you are accessing this website via a browser, for example, to remember a search you have undertaken or to remember what job you have applied for. The Session Cookies are cleared as soon as your browsing session is completed, you have logged off, or navigated to another website. We do not store your personal information under any circumstances.
For further information visit www.aboutcookies.org or www.allaboutcookies.org
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
Relevant legislation
Our website may contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
Data Breaches
We will report any unlawful data breach of this website’s database or the database(s) to all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
Your rights
Please be aware that you have the following data protection rights:
Where you have consented to Plum Personnel Ltd processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Julie Whitehouse, Director at julie@plum-personnel.com.
You can contact the Data Controller at Plum Personnel directly if you have any questions or concerns and if you are dissatisfied with how Plum Personnel Ltd uses your data the can make a complaint to the government body in charge Information Commissioner's Office at www.ICO.org.uk.
You have the right to ask Plum Personnel to amend or stop using your information and can at any time ask us for a copy of the information supplied by you that we hold.
If this involves a request for erasure of your file, please be aware that we may not be required or able to do so, particularly where your file also holds information about our clients or financial information that we need to keep for periods of up to 6-years for example where it relates to payroll or tax matters.
We may ask you to verify your identity and for more information about your request. We also have the right to charge a nominal administrative fee for this service.
Where we are unable to comply with your request we will provide reasons for failing to do so.
If you would like to make a request for information, please contact hello@plum-personnel.com.
Changes to the Privacy Policy
We reserve the right to modify this Privacy Policy at any time. Any changes we make in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice. Your continued use of our services and the website shall be deemed your acceptance of the varied Privacy Policy.
Any further questions?
We trust this Privacy Policy gives you the information and understanding of what we do with your data, where it is stored and how long for.
We value your privacy and will do our utmost to protect your data. If you have any further questions or concerns regarding any aspect of this document (or any other questions about our service for that matter) please contact your Plum Personnel representative, call into our office to speak to us or get in touch.
Changes to our privacy policy
We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was first published on 25 May 2018 and last updated on 24 September 2018.