Privacy Policy

Aspire Rec2Rec Ltd
PRIVACY NOTICE FOR CANDIDATES

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your working relationship with us.

We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003

This notice applies to current and former candidates, who we have either placed into a role temporary or permanent or who have contacted us/we have contacted about a prospective job role. You are being sent a copy of this privacy notice because you are applying, or have applied for work via us. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR)

References to we, our or us in this privacy notice are to Aspire Rec2Rec Ltd of 147a High Street, Waltham Cross, Hertfordshire, EN8 7AP.

Aspire Rec2Rec Limited is a limited company incorporated in England and Wales. Registered Number 9540059. Registered Office: 147a high Street, Waltham Cross, Hertfordshire EN8 7AP.

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation. Contact details are set out in the “Contacting us” section at the end of this privacy notice.

DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

1. Personal Information

In order to support your career aspirations and source new job opportunities for you, you may provide us with or we may obtain personal information about you, such as information regarding your:

  • personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
  • date of birth;
  • gender;
  • passport/driving licence details (including copies where we are required to hold such information for identification purposes);
  • employment history and location of current workplace, training and qualifications, salary, annual leave, pensions and benefits entitlement;
  • location of employment or workplace;
  • Immunisations and health check history;
  • any bank details you provide so that we can make payments to you and details of the financial transactions with you (for contractors/freelancers/locum staff;
  • start date, leaving date and pay rate for contractors/freelancers/locum staff;
  • recruitment (including references and other information included in a CV, cover letter or as part of the application process);
  • National Insurance Number
  • Online Check including, DBS, GMC, NMC, Mandatory Training,

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION

We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:

  • information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
  • information about your trade union memberships;
  • information about your health, including any medical condition, health and sickness records, medical records and health professional information and disability information; and
  • biometric information about you, for example fingerprints, retina scans.
  • Biometric Residence Permit
  • Criminal Convictions (For criminal records information in relation to you we process it on the basis of legal obligations or based on your explicit consent)

We may not collect all of the above types of special category information about you. In relation to the special category personal data that we do process we do so on the basis that:

  • the processing is necessary for reasons of substantial public interest, on a lawful basis;
  • it is necessary for the establishment, exercise or defence of legal claims;
  • it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or
  • you have provided your explicit consent.

In the table below we refer to these as the “special category reasons for processing of your personal data“.

3. WHERE WE COLLECT YOUR INFORMATION

We typically collect personal information about candidates when you fill in forms on or upload a CV onto our site at www.aspirerec2rec.co.uk or when you correspond with us by phone, e-mail or otherwise.

We also may collect personal information about candidates through other sources such as LinkedIn, job board websites, online CV libraries, personnel recommendations and referrals, hiring platforms and through the use of business development tools.

4. HOW WE WILL MAKE USE of YOUR information

  • We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
  • Where we need to comply with a legal obligation.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • We may also use your personal information in the following situations, which are likely to be rare:
  • Where we need to protect your interests (or someone else’s interests).
  • Where it is needed in the public interest.

We will use the personal information we collect about you to:

  • Assess your skills, qualifications, and suitability for prospective or specific roles
  • Carry out background and reference checks, where applicable.
  • Communicate with you about the prospective or specific role, and the recruitment process.
  • Keep records related to our client’s hiring processes.
  • Comply with legal or regulatory requirements.

We need to process your personal information for the purposes of the work-finding services you have instructed us to perform, and which we have a legitimate interest in, and to decide whether you are suitable for a prospective or specific role.

It is in our legitimate interests to decide whether you are suitable for a prospective or specific role due to the contracts we have with our clients, and it is in our legitimate interest to provide our clients with your personal information for that purpose.

When we have collected personal information about you, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to forward to the client for the prospective or specific role, but will only forward it to the client once you have provided your explicit consent. If the client decides to call you for an interview, we will use the information you provide to arrange the interview.

In some cases, the client will instruct us to carry out reference, background or criminal checks.

Information about Criminal Convictions

We may process information about criminal convictions.

We may collect information about your criminal convictions history if our client would like to offer you the work/ role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves, and our client, that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:

  • We are legally required to carry out criminal record checks for those carrying out  some roles
  • The some of the roles require a high degree of trust and integrity.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

Purpose

Personal information used

Lawful basis

Non – ‘special categories’ of Personal Information

To assess your CV and qualifications (where you have provided us with/we have collected your personal information directly from you)

All the personal information we collect for the purposes of the recruitment process.

We need this information to be able to perform and administer the recruitment process for you. It is in our legitimate interest to see if you are suitable for a particular role.

We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.

For criminal records history we process it on the basis of legal obligations.

To provide you with information regarding job opportunities that may be of interest to you based on your CV and qualifications (where you have provided us with/we have collected your personal information directly from you)

All the personal information we collect for the purposes of the recruitment process.

As above.

To contact you with information regarding job opportunities that may be of interest to you based on your CV and qualifications (where we have obtained your information from a third party source)

All contact details and all information contained in any CV (including employment and education history and location of current workplace).

Where your personal information has been sourced indirectly online from a third party such as a hiring platform or job board onto which you have uploaded your CV or where you have been referred to us for work, we have a legitimate business interest to do so.
In all other cases, we will only contact you with information where we have your explicit consent to do.

To share your CV, references or details of your qualifications and training with a client in relation to a particular job role

All the non-‘special categories’ of personal information we collect for the purposes of the recruitment process.

We need this information to be able to perform and administer the recruitment process for you.  It is in our legitimate interest to provide your CV to a client in relation to a particular job/role.

To share your online checks including GMC, NMC, Mandatory training, with a client in relation to a particular job role

All the non-‘special categories’ of personal information we collect for the purposes of the recruitment process.

We need this information to be able to perform and administer the recruitment process for you. It is in our legitimate interest to provide your training to a client in relation to a particular job/role.

To arrange an interview with/introduction to a prospective employer in relation to a particular job role and managing the introductory process, provided you have indicated that you are happy for an introduction to be arranged

All the non-‘special categories’ of personal information we collect for the purposes of the recruitment process.

We need to be able to perform and administer the recruitment process for you, including arranging an interview.  It is in our legitimate interest to provide to arrange an interview for you with a client in relation to a particular job/role.

To check you are legally entitled to work in the UK where instructed to do so by a client and National Insurance Number

Personal contact details and identification documents and right to work documentation

We have a legal obligation to do so, and it in our legitimate interest to ensure that you are entitled to work for the jobs you wish to apply for.

Storage of records relating to you and also records relating to our business

All non-‘special categories’ of personal information

We may have a legal obligation to do so and we also have a legitimate interest to keep proper records.

Dealing with legal disputes involving you.

All your personal information excluding ‘special categories’ of personal information and criminal records information

We have a legal obligation to do so.

We have a legitimate interest to ensure that all legal claims are managed effectively.

To send you information we think you might find useful or which you have requested from us, including information about our services and any events we are running, provided you have indicated that you are happy to be contacted for these purposes

Personal contact details

Where you have given us your explicit consent to do so.

‘Special categories’ of Personal Information or criminal records

Storage of records relating to you and also records relating to our business

All ‘special categories’ of personal information

We process special category personal data on the basis of the ‘special category reasons for processing of your personal data’ referred to in section 2 above.

For criminal records information we process it on the basis of legal obligations or based on your explicit consent.

We will use information about your physical or mental health to assess your suitability for particular roles based on health grounds

Information about your health, including any medical condition, health and sickness records, medical records and health professional information

We process special category personal data on the basis of the ‘special category reasons for processing of your personal data’ referred to in section 2 above.

We will use and retain information about criminal convictions to comply with law and in order to determine your eligibility to undertake particular types of work

Information about your criminal convictions and offences

For criminal records information we process it on the basis of legal obligations or based on your explicit consent.

If you fail to provide personal information

For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information.  If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to take your application further.

You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us, however you are aware that by the very nature of the task we perform we will not be able to assist you in work-finding services without consent, in some circumstances.  Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do soon bases other than your consent (as set out in the table above). Please be aware if you wish to withdraw consent for Aspire Rec2Rec Ltd to process your information, then we may need to cease communication with you and you will be required to start the entire registration process again of all personal information should you wish to enter into a future transaction with Aspire Rec2Rec Ltd.

5. DIRECT MARKETING

Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about products and services we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set, and upon receiving your consent. You can then let us know at any time that you do not wish to receive marketing messages by emailing us at info@aspirerec2rec.co.uk. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.

6. Disclosure of your PERSONAL information

We share personal information with the following parties:

  • Companies in the same group of companies as us: for the purpose of providing a service to you.
  • Any third party approved by you.
  • Customers of our business where necessary: For example, the client of ours for whom you wish to be considered for a prospective or specific role.
  • Other service providers to our business and advisors: for example payroll, email marketing specialists, business development tool providers, professional advisors, contractors, CCTV providers and administration and IT services (including CRM, website, video- and teleconference services). All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.
  • Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.
  • Prospective new employers: our clients for the purpose of introducing you as a prospective new candidate.
  • The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC or the Information Commissioner’s Office and GMC or NMC.
  • Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

We do not disclose personal information to anyone else except as set out above.

7. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws.  For further details please contact us by using the details set out in the “Contacting us” section below.

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section. 
Our directors and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are on holiday abroad outside of the UK or European Union.  If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.

In limited circumstances the people to whom we may disclose personal information as mentioned in the section “Disclosure of your personal information” above may be located outside of the UK and European Union.  In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed. 

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

8. HOW LONG WE KEEP PERSONAL INFORMATION FOR

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements.  Generally, where there is no legal requirement we retain all physical and electronic records for a period of 6 years after your last contact with us. Exceptions to this rule are:

  • Telephone and videoconferencing recordings which are held for no more than 30 days unless we need to preserve the records for the purpose of prevention and detection of crime;
  • CCTV records which are held for no more than 30 days unless we need to preserve the records for the purpose of prevention and detection of crime;
  • Information that may be relevant to personal injury claims, employment claims, discrimination claims may be retained until the limitation period for those types of claims has expired.  For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after you have worked for a client.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. You can update some of the personal information we hold about you by contact us using the details set out in the “Contacting us” section below.

9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

  • the right to be informed about how your personal information is being used;
  • the right to access the personal information we hold about you;
  • the right to request the correction of inaccurate personal information we hold about you;
  • the right to request the erasure of your personal information in certain limited circumstances;
  • the right to restrict processing of your personal information where certain requirements are met;
  • the right to object to the processing of your personal information;
  • the right to request that we transfer elements of your data either to you or another service provider; and
  • the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

10. DATA SECURITY

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-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

11. COOKIES

We may obtain data from cookies. These are small text files that are placed on an Individuals computer by websites. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.

Most web browsers allow some control of most cookies through the browser settings. Please note that in a few cases some of our website features may not function if cookies are removed from the internet browser

12. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

13. CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email info@aspirerec2rec.co.uk or write to us at Aspire Rec2Rec, 38 St Andrew Street, Hertford, Herts SG14 1JA