First created: 14.03.2018
Last reviewed: 13.11.2018
Last updated: 13.11.2018
Recann Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]|
|“Our Site”||means this website, recann.co.uk;|
|“UK and EU Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]|
|“We/Us/Our”||means Recann Ltd , a limited company registered in England under 09216630, whose registered address is Suites 13 – 16, 2nd Floor, Barton Arcade, Manchester, M3 2BH
|“You/Your”||means a data subject that has personal data that is to be processed or held by Recann Ltd|
|“Candidate”||means a data subject who is seeking employment|
|“Employer/Employee”||Means a data subject who works for a registered business|
- Information About Us
- Our Site, is owned and operated by Recann Ltd, a limited company registered in England under 09216630, whose registered address is Suites 13 – 16, 2nd Floor, Barton Arcade, Manchester, M3 2BH.
- Our data protection officer is Jon Jonathan Fisher who can be contacted at Jonathan@recann.co.uk
- We are a member of The Association of Professional Staffing Companies (APSCo). A membership group for the recruitment industry, committed to high standards of corporate and social responsibility.
- Scope – What Does This Policy Cover?
- What Data Do We Collect?
- date of birth;
- telephone number;
- business/company name
- job title;
- contact information such as email addresses and telephone numbers;
- demographic information such as preferences and interests;
- Work History provided by you or by collection from 3rd Party services (see section 6 for 3rd party services we use)
- IP address (automatically collected);
- web browser type and version (automatically collected);
- operating system (automatically collected);
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
- How Do We Use Your Data?
- All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
- We use your data to provide the best possible services to you. This includes:
- Providing and managing and up to date recruitment service with a dedicated account manager
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying up to date and relevant job listings for you;
- Responding to communications from you;
- Supplying you with email newsletters e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking on the unsubscribe link at the bottom of every email;
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
- In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on job listings, candidates and potential employers. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
- Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights or having an adverse effect on your personal data. We will only process your personal data if at least one of the following basis applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are the subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- processing is necessary for the purposes of the legitimate interests pursued by us, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data. This would be in circumstances where jobs may be deemed relevant to a candidate or candidates would be a potential applicant for a potential employer.
- If you are a potential candidate looking for employment, We may hold or process your data and will foresee this action operating within your legitimate interests. We will ask for your permission and active consent to share your details, as listed in section 4, with potential employers. Should you no longer wish for your details to be shared in this way please let Us know or email firstname.lastname@example.org.
- You are within your rights under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015 regulations to declare which personal details we share with potential employers. For example, only phone number and name or only name and email address.
- If you are an employer looking for suitable candidates, we will only share and process data on an individual who has given us express permission and active consent to do so.
Similarly, we will only share your personal data, as a potential employer, with your prior active consent. Should you no longer wish for your details to be shared in this way please let Us know or email email@example.com.
- How and Where Do We Store Your Data?
- We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct a quarterly review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies and where we collect and store tour data are:
- Filing cabinets – Some of your data, such as a CV or work history may be stored on premises in locked filing cabinets. These can be accessed by Recann staff only.
- Staff computers – Every staff member has access to a computer and your data may be stored on these computers. Every computer is password protected. Please see our security Policy for further information about our computer security.
On each device data may be stored on a local hard drive, on saved temporary Outlook folders and in a contact database. Every computer is connected to a central network, where shared drives can be accessed by all staff. Your data will most likely be shared on this drive and be shared between staff members.
- Staff mobile telephones – Contact information, such as name, job title will be stored on staff mobile phones. Staff will have access to stored data from their phones.
- LinkedIn Connections – We process, store and have access your data through LinkedIn. Once contact, LinkedIn connection or an employment need is established We will often copy contact data such as Name, email address, phone number and work history to any data storage location listed in this section.
Please follow our right of erasure or data access request procedures should you wish to change how we process your data through LinkedIn.
- BullHorn CRM – We use Bull Horn CRM for customer management and help match candidates with appropriate positions. The data will be stored securely and is protected by Privacy Shield protocols. Bull Horn are committed to protecting your data and will be compliant with GDPR legislation. https://www.bullhorn.com/gdpr-commitment-statement/
- Broadbean – We use Broadbean online recruitment software for job posting and distribution, CV database search, social referral, job alerts, data analysis. Please see their commitment to GDPR regulations http://info.broadbean.com/broadbean-gdpr.
- Lusha – We are using Lusha to enrich social profiles and attribute contact details to social media profiles. We will occasionally copy details from Lusha to notify data subject of relevant jobs. Please find Lusha’s commitment to GDPR regulations: https://www.lusha.co/gdpr.
- Excel spreadsheets – We use spreadsheets to cross reference candidate data to make sure we manage jobs, candidates and employers efficiently.
- io – We use Hunter.io or email hunter to verify correct email addresses against a pseudonomysed and speculative email address verification process. Please see hunter.io commitment to GDPR – https://hunter.io/gdpr
As a recruiter we have access to candidate and employer data via the
Following 3rd Party locations.
- Reed – Reed is an online job portal and recruitment service. We use Reed to post jobs, find candidates and match them to job opportunities for employers. Reed data storage policies can be found here: https://www.reed.co.uk/policies. We will often process data from Reed by copying contact information from the service and matching these to our current records or creating a new data subject record to match
- CV Library – We use CV Library to post jobs, find candidates and match them to job opportunities for employers. CV Library’s data storage policies can be found here: https://www.cv-library.co.uk/gdpr-statement. We will often process data from CV Library by copying contact information from the service and matching these to our current records or creating a new data subject record to match candidates to jobs.
- Stepstone & its Subsidiaries (CW Jobs, Total Jobs, JobSite, Mahiba) – We use CW Jobs, Total Jobs and JobSite to post jobs, find candidates and match them to job opportunities for employers. This group’s data storage policies can be found here: http://recruiters.cwjobs.co.uk/page/gdpr, https://www.totaljobs.com/privacy-policy, https://www.jobsite.co.uk/privacy We will often process data from this group of websites by copying contact information from the service and matching these to our current records or creating a new data subject record to match candidates to jobs.
- Monster Jobs – We use Monster to post jobs, find candidates and match them to job opportunities for employers. Monster’s data storage policies can be found here: http://inside.monster.co.uk/fullpolicy/inside2.aspx. We will often process data from this group of websites by copying contact information from the service and matching these to our current records or creating a new data subject record to match candidates to jobs.
- Your data will be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).AND
- Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. [If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand and we have put in place the following safeguards to protect your data:
We have installed the following software to protect your data on all our devices, server and business infrastructure:
Avast Business CloudCare Suite which has the following notable components:
- File Shield – Monitors all files and blocks any dangerous or malicious files
- Behaviour Shield – Identifies apps acting suspiciously in real time
- Mail Shield – monitors mail in and out and blocks infected mail
- Web Shield – stops malware and spyware from websites
- Real Site – stops browsing to forged websites
- Anti-spam – blocks spam from mailboxes
- Firewall – monitors in and out bound activity
- VPN – gives a secure connection when using public hotspots
- Data Shredder – overwrites files with encrypted data to permanently delete.
And in order to administer these services we also consistently monitor via the cloud and notifies administrators when threats are detected, and components are disabled as well as missed scans and updates etc.
- Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
- Steps We take to secure and protect your data include:
- Identifying compromised hardware and this will be taken offline.
- Investigations of compromised hardware will be carried out to identify cause.
- We will determine scale of breach and detail what has been compromised, and how and by whom.
- We will then carry out relevant work to secure hardware.
- A full Report will be given to Recann’s GDPR officer.
- You can expect a full report of your data that has been compromised within 3 working days.
- Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
- Do We Share Your Data?
- If relevant and with your prior active consent, we may share your data with other companies in Our group and potential relevant employers and potential relevant candidates. This includes our sister company Recann Dynamics, that recruits Microsoft Dynamics developers.
- If relevant and with your prior active consent, we may share your data with companies who have relevant job openings for each job.
- We may contract with third parties to supply some services to you on Our behalf. These may include payment processing, search engine facilities, advertising and marketing. In every circumstance your data will be encrypted and only contractors who have been thoroughly vetted will be able to see your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:
Andrew Balerdi GDPR and Marketing Consultant
CDA Business Services Ltd.
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
Any numerical and statistical data such as this will be anonymised.
- In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
- What Happens If Our Business Changes Hands?
- In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
- How Can You Control Your Data?
- When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by managing your Account email subscription preferences.
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
- You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
- You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible recruitment services to you.
- How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org or using the contact details below in section 14.
- What Cookies Do We Use and What For?
- By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site to collate information on potential candidates or employers. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.
- All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.
- Before Cookies are placed on your computer or device, subject to section 12.5 AND/OR section 12.8, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to block or allow cookies.
- Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
- The following first party Cookies may be placed on your computer or device. These are from Google and to opt out click here: https://tools.google.com/dlpage/gaoptout:
|Name of Cookie||Purpose||Strictly Necessary|
|PHPSESSID||To establish a connection and track user’s sessions anonymously. It expires when the browsing session ends and will inform our server that a session has taken place.||Yes|
|_ga||This is google analytics’ first party cookie that registers the Recann analytics account via domain and sets the cookie expiration.||Yes|
|_gat||Used to throttle request rate
|_gid||Used to distinguish users||Yes|
and the following third party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
|DSID||Google/DoubleClick||This distinguishes users who have come from the DoubleClick network and assigns them an anonymous ID|
|IDE||Google/DoubleClick||These cookies set by a third party (DoubleClick) and are used for serving targeted advertisements that are relevant to you across the web. Targeted advertisements may be displayed to you based on your previous visits to this website. For example, advertisements about a topic you have expressed an interest in while browsing our site may be displayed to you across the web. In addition, these cookies measure the conversion rate of ads presented to the user. For more information, please visit www.google.com/policies/privacy/partners/ If you wish to disable DoubleClick cookies on your browser please visit this website
|cto_lwid||Google/DoubleClick||A session ID cookie to register the session.|
|AMCV_14215E3D5995C57C0A495C55%40AdobeOrg, ELOQUA, _ga, _guid, _lipt, _bcookie, lang, liap, lidc, sdsc||WE use multiple cookies from LinkedIn. These are in use to track user’s behaviour, (e.g clicks from ads, pages visited) demographic information (e.g your job title and location) and we may use this information to connect with you on LinkedIn.|
- Our Site uses analytics services provided by Google, Facebook. LinkedIn, Twitter and AddThis. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
- The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.
- You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed.
In Chrome type the following in your address bar: chrome://settings/clearBrowserData and follow the instructions to delete, edit or change your permissions.
In Firefox go to about: preferences#privacy, the menus will then direct you where to go.
Follow these instructions from Microsoft for Internet Explorer and Microsoft Edge Browsers: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
For Safari follow these instructions from Apple: https://support.apple.com/kb/PH21411?locale=en_US
For further details, please consult the help menu in your internet browser or the documentation that came with your device.
- You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
- It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
- Summary of Your Rights under GDPR
Under the GDPR, you have:
- the right to request access to, deletion of or correction of, your personal data held by Us;
- the right to complain to a supervisory authority;
- be informed of what data processing is taking place;
- the right to restrict processing;
- the right to data portability;
- object to processing of your personal data;
- rights with respect to automated decision-making and profiling (see section 14 below).
- Automated Decision-Making and Profiling
In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
13.1 The right described in section 14.1 does not apply in the following circumstances:
- The decision is necessary for the entry into, or performance of, a contract between the You and Us;
- The decision is authorised by law; or
- You have given you explicit consent.
- Where We use your personal data for profiling purposes, the following shall apply:
- Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- Appropriate mathematical or statistical procedures will be used;
- Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
- We currently make the following automated decisions:
Email capture through forms on the site. Contact details found through Lusha browser extension, Bullhorn CRM data segmentation, LinkedIn data processing via keyword matches and user database matching.
13.4 We currently profile your personal data for the following purposes:
Job requirements, job matching, salary expectations and recording previous or current salary.
- Contacting Us