Welcome to Placed Recruitment Ltd’s privacy notice.
Placed respects your privacy and is committed to protecting your personal data as users of our website, our mobile recruitment app (“our App”) and otherwise as our business contacts. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our App or otherwise engage with Placed and it tell you about your privacy rights and how the law protects you.
Please use the Glossary at the end of this policy document to understand the meaning of some of the terms used in this privacy notice.
- Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Placed collects and processes your personal data through your use of this website, your use of our App (either as a candidate or as a hirer) or otherwise when you engage with Placed, including any data you may provide through this website when you sign up to our newsletter, engage with us on our blogs, articles, competitions, forums or social media, you use our technology and services to seek work or to hire staff or otherwise do business with us in some way. There is a separate privacy notice for our own staff and contractors.
Our website and App and services are not intended for children and we do not knowingly collect data relating to children who are under 18.
It is important that you read this privacy notice together with any other privacy notice or policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other current or future notices and privacy policies and is not intended to override them, except when stated otherwise.
Data protection principles
We will comply with data protection law and principles, which means that your data will 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.
Placed Recruitment Ltd is the controller and responsible for your personal data (collectively referred to as “Placed” “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy team which is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights set out below, please contact the data privacy team using the details set out below.
If you have any questions about this privacy notice or our privacy practices, please contact our data privacy team in the following ways:
Full name of legal entity: Placed Recruitment Limited
Email address: email@example.com (address your correspondence to the “data privacy team”)
Postal address: V401 Vox Studios, 1-45 Durham Street, SE11 5JH
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. This version was last updated on 15th September 2020. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details where relevant to individuals engaging with us.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, to the extent that might be relevant to any individual engaging with us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website or our App.
- Profile Data includes your photograph (if used by you), username and password, purchases or orders or job applications made by you, your interests, preferences, feedback and survey responses and any social media tags or personal data you share with us via social media.
- Usage Data includes information about how you use our website, App, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Candidate Recruitment Data includes, but only where you are a work seeker using our App for work finding purposes, data in connection with your registration on our App and use of it to seek work with hirers and which may include the following categories of personal information about you:
- The information you have provided to us in your registration with our App and in any documents you attach with your registration or otherwise send to us, such as your curriculum vitae and any covering letters or in any job application form through our App including name, title, address, telephone number, personal email address, date of birth, gender, employment history and current roles, skills, languages spoken, qualifications, and salary/role/opportunity/industry expectations.
- Any information you provide to us or hirers through any communication functions on our App or otherwise to us outside of our App or third parties such as hirer clients or your current and ex-employers might provide to us such as references and confirmation of job history data.
- Information about your race or ethnicity and right to work in the UK, religious beliefs, sexual orientation and political opinions, where it is appropriate for us to process such data.
- Information about your health, including any medical condition, health and sickness records, where it is appropriate for us to process such data.
- Information about criminal convictions and offences, where it is appropriate for us to process such data.
We also collect, use and share aggregated data of our users such as statistical or demographic data for any purpose. Such aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Except in appropriate circumstances in respect of Candidate Recruitment Data, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Except in appropriate circumstances in respect of Candidate Recruitment Data, we do not collect any information about criminal convictions and offences.
Where we process Special Categories of Personal Data and criminal records data of candidate users of our App for reasons related to employment, we have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial, Marketing and Communications and Candidate Recruitment Data by registering with our App, filling in forms or by corresponding with us by post, phone, email or otherwise or directing us to your website or social media accounts. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website or App;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Candidate Recruitment Data from our hirer clients who you engage with through our App and also your current and ex-employers.
- Technical Data from the following parties:
- analytics providers such as Google in Europe/UK;
- advertising Facebook and Instagram in Europe/UK; and
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services in Europe/UK.
- Identity and Contact Data from data brokers or aggregators in Europe/UK.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU and your own company’s website as applicable.
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal obligation.
Please see the explanation of “Lawful Basis” in the Glossary at the bottom of this privacy notice to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
||Type of data
||Lawful basis for processing including basis of legitimate interest
|To register you as a new client / App user / supplier
(d) Candidate Recruitment
|Performance of a contract with you/your company
|To process your order (mainly for hirers and not for data subjects who are candidate users of our App) including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you/your company
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you and provide our services through our website and App, which will include:
(a) Notifying you about changes to our terms or privacy notices and policies
(b) Asking you to leave a review or take a survey
(c) Providing the functionality for you to use our App and website for your purposes
(e) Marketing and Communications
(f) Candidate Recruitment
|(a) Performance of a contract with you/your company
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
|(a) Performance of a contract with you/your company
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business, our website and our App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and seeking legal and other professional advice in respect of our business)
(e) Candidate Recruitment
|(a) Performance of a contract with you/your company
(b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(c) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage, Profile and Candidate Recruitment Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers or job opportunities may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We do not share your data to others for them to market to you, unless it is our data processor acting on our instructions for our marketing purposes and in which case the provisions of this privacy notice apply.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, we will still hold and process personal data about you in accordance with this privacy notice.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Automated Decision Making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights. We use Candidate Recruitment Data (such as location, qualifications, experience, job hunt status and languages spoken (if relevant for role), although no special categories of data) in automated decision making to match candidates with roles. We do not match candidates with roles using traditional means involving our staff. Our platform, pricing, business model and plans for scale are based around that approach and so it is necessary for our contract with candidates that we apply automated decision making for those matching purposes.
If we make an automated decision on the basis of any special categories of personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights. We do not currently use special categories of data as part of our automated decision making process.
If you have any issue with our matching service and so our use of automated decision making, please contact our data protection team and a member of the team will be assigned to investigate your query and provide human intervention to test the particular decision given by automated means.
- Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary. We do not sell your data to any such third parties. Any transfers are necessary and/or lawful for the purposes set out in this privacy notice.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
To the best of our knowledge, we do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions or their mandatory legal requirements and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, and often that is for 6 years given limitation periods on legal and tax matters. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data will be made available on request.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary below under “Your Legal Rights” to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact our data privacy team mentioned above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Any other companies in our corporate group from time to time. At present there are no such other companies.
External Third Parties
- Other users. Candidate data will be shared with hirers and which may involve transfer of candidate data to the hirer’s processors, such as their service providers, advisors, HR and Applicant Tracking technology providers. Candidates should seek relevant privacy notices from hirers as hirers in that case will then be independent controllers, using the data for their own purposes. Contact details and information about hirer staff may be shared with candidates.
- Service providers acting as processors based in the UK and Ireland who provide IT and system administration services, such as Amazon Web Services.
- Professional advisers acting as processors or joint or independent controllers including lawyers, bankers, auditors and insurers based in the UK only at present who provide consultancy, banking, legal, insurance, marketing, and accounting and other professional services.
- HM Revenue & Customs, regulators and other authorities acting as independent controllers based in the UK only at present who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.