PRIVACY NOTICE

Privacy Policy for O’Connell Resourcing Limited and OCR Alpha Limited – commonly referred to as “OCR”.

 

O’Connell Resourcing Limited (07106441) and OCR Alpha Limited (09281626) (hereafter referred to jointly as “OCR”) is registered as a data controller in the United Kingdom for the purposes of the Data Protection Act 2018. OCR’s website is designed to protect the privacy of all users. We ensure that the data you supply to us is processed fairly and lawfully, and with skill and care. This Data Protection Policy governs our processing of all personal data provided to us, in all forms. By registering your details with us and using our website, you consent to us collecting and processing personal data supplied by you and disclosing this information to prospective employers and clients in connection with the recruitment process. 

 

INTRODUCTION 

This Privacy Notice provides you with clear information as to how we process your personal data. We are obliged to use your information in line with all applicable laws. We do so in a manner that is fair by using your information in a way that you would reasonably expect when providing our work-finding services or recruiting personnel for you, and being transparent so that you know how it will be used. 

 

This Privacy Notice sets out: the types of personal data that we collect about you; how and why we use it; how long we will keep it for; when, why and with whom we will share it; the legal basis for us using your personal data; and your rights in relation to us storing and processing your personal data. It also explains how we may contact you and how you can contact us. 

 

Part of the recruitment process will involve sharing your personal data with our clients (independent data controllers) who have potential work opportunities that may be suitable for you. These third parties will have their own privacy policies and will also need to comply with all applicable laws. We encourage you to contact them directly if you have any concerns or questions about your data. 

 

WHO WE ARE 

OCR is a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Business Regulations 2003 (our business). We provide both temporary and permanent recruitment services to clients looking to recruit personnel for their business and provide work-finding services to candidates looking for job opportunities. We also occasionally provide the following other services, training and consultancy. We collect the personal data of the following types of people to allow us to undertake our business; 

  • Prospective and placed candidates for permanent or temporary roles; 

  • Prospective and live client contacts; 

  • Supplier contacts to support our services; 

  • Employees and external consultants. 

 

We are registered as a data controller with the ICO in the United Kingdom for the purposes of the Data Protection legislation and General Data Protection Regulation (GDPR). Our registered office address is 2 Stephen Street, Fitzrovia, London, W1T 1AN and our Data Protection Officer is Peter O’Connell who can be contacted at peter(at)oconnellresourcing(dot)com if you have any queries relating to data protection. 

 

LEGAL BASIS FOR PROCESSING YOUR DATA 

Our legitimate interests in collecting and retaining your personal data is described below: 

  

As a recruitment business we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process. 

  

In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements. 

  

To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts. In turn, we look to share market and industry related material which we produce to assist both the candidates and clients registered in our database. 

 

We do not consider our legitimate interests to be overridden by your interests or fundamental rights and freedoms. We take into consideration the reasonable expectations of individuals who are actively applying for jobs or making their personal information publicly accessible on professional networking sites. 

 

If you are submitted as a candidate or requested for interview, then this may involve the processing of more detailed personal data including sensitive data such as health information or any unspent criminal convictions that you or others provide about you. We will ask for your consent before undertaking such processing if we are required to do so. 

 

For clients, it may also be necessary for us to process your data in order to perform a contract for you if one is in place, for example in contacting you. 

 

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate). 

 

WHAT INFORMATION WILL WE COLLECT ABOUT YOU? 

We collect and process personal data only as far as is necessary to facilitate the recruitment process and provide you with work-finding services. We need your personal data in order to find you suitable opportunities and further information may be needed to assess your eligibility through the different stages of the recruitment process. 

 

The information we collect may include your name, email address, telephone number, CV, identification and right to work documents, educational records, work history, employment and references. 

 

In general, we will not ask you about sensitive personal data but there may be times when it is necessary for information to be disclosed to us and for us to share it with potential employers. We will only share the information where you have provided your explicit consent. 

 

We are also under an obligation to our clients to provide suitable candidates. Part of the assessment process will include asking you about any unspent criminal convictions you may have. We consider this to be highly confidential information and will only do so where you have provided your explicit consent. 

 

Candidate Data: We may collect some or all of the information listed below to enable us to suggest you employment opportunities which are tailored to your circumstances and your interests: 

  • Name; 

  • Age/date of birth; 

  • Sex/gender; 

  • Photograph; 

  • Marital status; 

  • Contact details; 

  • Education details; 

  • Employment career history; 

  • Reference information; 

  • Immigration status (your right to work in the United Kingdom); 

  • Nationality/citizenship/place of birth; 

  • Diversity information including racial or ethnic origin; 

  • Details of any criminal convictions; 

  • Details about your current remuneration, pensions and benefits arrangements; 

  • Information on your interests and needs regarding future employment; 

  • Extra information that you choose to tell us; 

  • Extra information that your referees chooses to tell us about you; 

  • Extra information that our Clients may tell us about you, or that we find from other third-party sources such as job sites, and 

  • The dates, times and frequency with which you access our services. 

  

Please note that the above list of categories of personal data we may collect is not exhaustive. 

  

Client Data: The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your engagement with our Candidate profiles and other material published by OCR, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold additional information that someone in your organisation has chosen to tell us. 

 

WHERE DOES THE INFORMATION WE COLLECT ABOUT YOU COME FROM? 

The data we collect about you is obtained from the following sources: 

 

  • Directly from you. This may be via our registration process, information requests and applications via our website or other online application portals. 

  • With regard to each of your visits to our site we may automatically collect the following information: 

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version; 

  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number. 

  • An agent or third party acting on your behalf. This may be where you are consulting via a Limited Company. 

  • Publicly available sources. We may also obtain your information from professional networking sites or job boards, where you have actively published or submitted your information. 

  • This is information which we obtain about you from additional sources such as Linked In, corporate websites, job board websites such as Efinancial Careers, online CV libraries such as Efinancial Careers, your physical business card and personal recommendations.  

  • Reference or word of mouth. You may be recommended by a friend, former employer or colleague. 

 

WHO WILL WE SHARE YOUR INFORMATION WITH? 

In order to provide work-finding services to you, it is necessary for us to share your personal data with our clients (independent data controllers) who have potential work opportunities that may be suitable for you. Once your data has been shared with them, they will determine how they use, store and process your data and will have their own privacy policy. 

 

There may also be circumstances where disclosure is required or permitted by law (such as to government bodies and law enforcement bodies). As an example, we are under an obligation to report pay details of all workers we place with clients to HMRC. 

 

Generally, we will process your information within OCR. There may be occasions where we use third parties to process your information on our behalf. In such situations these third parties will be under strict instructions and they will not be permitted to use your information for their own business purposes. 

 

We will share your personal information with: 

  • Any member of our group both in the EEA and outside of the EEA. 

  

Selected third parties including: 

  • Clients for the purpose of introducing candidates to them; 

  • Candidates for the purpose of arranging interviews and engagements; 

  • Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you; 

  • Subcontractors including email marketing specialists, data administrators, event organisers, payment and other financial service providers; 

  • Analytics and search engine providers that assist us in the improvement and optimisation of our site; 

  • Credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you. 

  

We will disclose your personal information to third parties: 

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets. 

  • If OCR or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. 

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use; or to protect the rights, property, or safety of OCR, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 

  

The lawful basis for the third party processing will include: 

  • Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs; 

  • Satisfaction of their contractual obligations to us as our data processor; 

  • For the purpose of a contract in place or in contemplation; 

  • To fulfil their legal obligations. 

 

We may also analyse the data internally so that we can offer a more relevant service, for marketing and strategic development purposes or for research purposes to improve our service. 

 

HOW AND WHEN WILL WE CONTACT YOU? 

We may contact you by phone, email or social media platforms such as Linked In 

 

Some examples of when we will contact you are: 

  • Upon receipt of a CV or your personal data, it will be reviewed to determine whether we are likely to be able to provide you with work-finding services and we will notify you if you are added to our database. 

  • When one of our consultants considers you for a suitable job opportunity or to find out more about the type of role you are looking for. 

  • Before we put you forward for a role. 

  • During and following an assignment we have placed you in. 

  • In relation to any correspondence we receive from you. 

  • To update you on any material changes to our policies and practices. 

 

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION? 

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining. 

  

We do the following to try to ensure our data is accurate: 

  • prior to making an introduction we check that we have accurate information about you 

  • we keep in touch with you so you can let us know of changes to your personal data 

  

We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes: 

  • the nature of the personal data; 

  • its perceived accuracy; 

  • our legal obligations; 

  • whether an interview or placement has been arranged; and 

  • our recruitment expertise and knowledge of the industry by country, sector and job role. 

  

We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so. 

  

For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms. 

  

We will delete your personal data from our systems if we have not had any meaningful contact with you (or where appropriate, the company you are working for or with) for four years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected. 

  

For those Candidates whose services are provided via a third party company or other entity, “meaningful contact” with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you. 

  

When we refer to “meaningful contact”, we mean for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate we will consider there to be meaningful contact with you if you submit your updated CV onto our website or apply to a position we have advertised. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly. 

 

WHAT ARE YOUR RIGHTS? 

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes. 

  

You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at  or  

  

From time to time our site may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. 

  

The GDPR provides you with the following rights. To: 

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. 

  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 

  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. 

  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. 

  • Request the transfer of your personal information to another party in certain formats, if practicable. 

  • Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/ 

  

ACCESS TO INFORMATION: 

You have the right to be informed about, and access a copy of, the information comprised in your personal data. If any of the data we hold is inaccurate, you have the right to rectify it. You can contact us at peter(at)oconnellresourcing(dot)com to update your data. 

 

You can make a request to find out what personal data we hold about you. You may exercise this right by making a written subject access request (SAR) to peter(at)oconnellresourcing(dot)com. We require you to provide us with proof of your identity and answer security questions before processing your request. 

 

We usually act on such requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for: 

  • baseless or excessive/repeated requests, or 

  • further copies of the same information. 

 

Alternatively, we may be entitled to refuse to act on the request. 

 

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.  

 

COOKIES:

Our website may use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. 

 

CHANGES TO OUR PRIVACY POLICY: 

Any changes we make to our privacy notice 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. 

  

CONTACT:

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to peter(at)ocralpha(dot)com or peter(at)oconnellresourcing(dot)com