Your right to privacy is very important to Oxford Knight. Oxford Knight is subject to the General Data Protection Regulations and accompanying legislation (since 25 May 2018). The following policy sets out how Oxford Knight manages personal data securely that is held about you (“you”) as an individual.
For the purposes of the legislation, the data controller is Oxford Knight Limited (a company registered in England & Wales, under registration number: 07261762) (“us/we/our”) Details of our notification to the UK Information Commissioner’s Office Public Register of Data Controllers can be found at www.ico.org.uk under registration number Z2732761.
Personal data is any data which relates to you as an individual and where you can be identified from that data or from a combination of that data and other information which is in possession of us as a data controller and which also includes any expression of opinion about you as an individual and any indication of the intentions of us as data controller or other persons or entities in respect of you as an individual (“Personal Data”).
Personal Data may range from very sensitive, to everyday information. This may include the opinions of others about your performance in the work environment, work experience, qualifications, assessment results and other data obtained by Oxford Knight in connection with potential work placements.
Such Personal Data may be collected from you when you: (a) visit www.oxfordknight.co.uk or www.oxfordknight.com (our main websites); or https://www.rekrvt.com (together “the Websites”), (b) register an account with us; and/or (c) apply for any job vacancies advertised on the Websites.
Sensitive personal data
Personal Data may include sensitive personal data (“Sensitive Personal Data”). We shall only collect, use or disclose Sensitive Personal Data (as defined under the legislation) about you in accordance with the law. In most cases, we shall only collect, use or disclose Sensitive Personal Data where it has received your explicit consent.
Such Sensitive Personal Data may include information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health or sexual and/or information relating to any criminal convictions you have or offences you may have committed (“Criminal Records Information”). By completing any Equal Opportunities Monitoring enquiry provided to you by us and/or by providing us with any Criminal Records Information you will signify your explicit consent to such Sensitive Personal Data being processed by us. Please note that the answers to all questions on any Equal Opportunities Monitoring enquiries are optional and you can always provide a “prefer not to say” response. However, we may be required to obtain Criminal Records Information from you in order to assess your suitability for certain job vacancies; if you do not wish to provide your Criminal Records Information then you hereby agree that we may be unable to process your application any further.
Collection of personal data
We are a recruitment consultancy placing candidates on a permanent and contract basis.
For the purposes of the UK Conduct of Employment Agencies and Employment Business Regulations 2003 (the “Conduct Regulations”) we operate as:
- An agency when recruiting for permanent positions or fixed-term assignments direct with our client(s); and
- An intermediary when recruiting for temporary assignments where services will be supplied to our client(s) via us
We shall be bound by applicable terms of the UK Employment Agencies Act 1973 and the Conduct Regulations, unless you do not act for and under the control of our client(s) when providing your services via us or you provide services via a separate company and you and that company have agreed to opt out of the application of the Conduct Regulations.
Your Personal Data shall be collected by us to provide you with recruitment and/or related intermediary services.
You also agree that we may also collect your Personal Data on behalf of and transfer it to Oxford Knight Resourcing Limited ((a company registered in England & Wales, under registration number: 09634782), a connected company under UK legislation (and with ICO registration number ZA148401), in connection with the provision of recruitment and/or related intermediary services to or for you.
Generally, we shall collect Personal Data directly from you, via electronic means or otherwise. For example, Personal Data is collected when you:
- Supply a CV or application form;
- Fill out and submit a registration form;
- Submit any other information in connection with your application;
- Complete psychometric assessments
Personal Data about you may also be collected from third parties that we contact for verification or vetting purposes. For example when we receive, via electronic means or otherwise:
- Any reference about you;
- Publicly available data e.g. LinkedIn/Job boards;
- Results of enquiries of former employees or engagers, work colleagues, professional associations or registration bodies;
- Results of any psychometric, competency or medical test;
- Performance feedback;
- Any complaint from or about you in the workplace;
- Any information about a workplace accident in which you were involved;
- Any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved.
We shall normally require you to provide signed consent to enable us to obtain Personal Data from third parties (unless you have indicated your consent in some other way) but, if we do not have your prior consent, we shall take reasonable steps to inform you as soon as possible that we have collected Personal Data from a third party and ensure you are aware of the purposes for which we have collected your Personal Data.
Use and disclosure of personal data
- To provide recruitment and/or related intermediary services to or for you and to facilitate the recruitment process;
- To match your details against job vacancies which we feel may be appropriate for you in order to assess your suitability for them;
- To apply for jobs on your behalf by sending your data to clients;
- To market our recruitment services to you;
- To develop and market other products and services, to improve our customer service and make our services more useful to you;
- To inform you about any relevant industry developments, send you details of any events, promotions and competitions, and to communicate any other relevant information;
- To maintain and promote our business relationships;
- To answer your enquiries or questions;
- For other purposes for which you have engaged us;
- For our own market intelligence gathering purposes, to enable us to understand the recruitment market and prepare demographic, analytical, statistical or market information (which may include aggregating your data with, and benchmarking it against, data received from other individuals, clients and employers) and to improve our services (all on the basis that your personal data will be completely anonymised and you will not be capable of being identified from such information if we share it externally)
We may also disclose your Personal Data to third parties if they have a proper interest in the disclosure, such as:
- A connected, associate or group company of ours also registered on the UK Information Commissioner’s Office Public Register of Data Controllers or EU equivalent register;
- Prospective employers or engagers;
- External vetting bodies;
- Third parties who perform functions on our behalf and who also provide services to us;
- Our insurers and professional legal representatives in the event of any disputes arising;
- A professional associated or registration body or regulatory or law enforcement agencies if we are required to do so by law.
If we engage a third party contractor to perform services which involve handling or processing your Personal Data, we shall take reasonable steps to prohibit the contractor from using such Personal Data except for the sole purpose for which it was supplied or for processing it other than in accordance with our instructions.
We may share your Personal Data with third parties 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 any contract with you or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; We may also make such disclosure to third parties if necessary in connection with any law (including any investigation or complaint regarding your use of the Websites).
If we or any of our associate or group companies enters into a joint venture with, is sold to or merged with another business entity, your Personal Data may be disclosed to our new, or potential, business partners or owners, by way of transferred assets. By providing us with your personal data, you expressly consent to us in disclosing your Personal Data to our new, or potential, business partners or owners if one of these situations arises.
If you do not provide us the Personal Data that we seek (provided that the data requested is reasonable and relevant to the services being provided to or for you), we shall be unable to provide you with recruitment and/or related intermediary services.
You have the right to be told the legal basis and purposes for the processing of your Personal Data. We are relying on your explicit consent to the processing of your Personal Data (including any Sensitive Personal Data, as set out above). This means that if you exercise your right to withdraw your consent we shall no longer be able to process your Personal Data. Please note we may retain a copy of your Personal Data (including your non-Personal Data) in accordance with our data retention policy (available upon request).
Security of personal data
We hold Personal Data in a combination of service computer storage facilities and paper-based files.
We have security procedures in place to protect the Personal Data it holds from misuse, loss, unauthorised access, modification or disclosure.
We use a number of processes to protect your personal data including:
- Locks and security systems;
- Computer passwords and limited access to shared network drives to authorised staff;
- Virus checking;
- Auditing procedures and data integrity checks;
- Recording of file movements;
- Anonymisation of data.
We shall keep your Personal Data no longer than necessary and shall appropriately dispose of your Personal Data when it is no longer required or if you ask for it to be removed from our systems so that it is protected from unauthorised use or disclosure.
We are however obliged under the Conduct Regulations (where applicable) to keep a record of your Personal Data and other information for a period of at least one year from the data of creation of the record or, if later, at least one year after the data on which we last provided services to you.
Requesting access to your data
You may request access to any Personal Data we hold about you in accordance with the Act.
We are not always required to provide you with access to all of your Personal Data on request.
We may refuse your access to certain Personal Data in a number of circumstances, such as where denying access is required or authorised by law.
If we deny your request for access we shall provide you with reasons for the refusal within a reasonable time period.
Updating your personal data
We take reasonable steps to ensure that your Personal Data is accurate, complete and up to date.
We may also contact you from time to time to check that the Personal Data is still correct. However, please let us know of any changes to your details as soon as you reasonably can in order for us to maintain the accuracy of your Personal Data.
If you believe that Personal Data generally or Sensitive Personal Data we hold about you is not accurate, complete and up to date, inform und we shall take reasonable steps to correct it.
If you wish to suppress or restrict the further use of your Personal Data please contact us via firstname.lastname@example.org. When processing is suppressed or restricted, we can store your information, but may not use it further. A record of individuals who have asked for further use of their information to be suppressed or restricted shall be maintained.
Upon request, we shall delete or remove your Personal Data in the event that there is no compelling reasons for us to keep using it. However, this is not a general right to erasure.
See Your Rights at paragraph 10 below for further details.
Transfer of personal data outside of the EEA
The Personal Data that we collect from you may be transferred outside of the EEA either by us and/or by any of the third parties to whom your Personal Data may be disclosed to as listed in the section “Use and disclosure of personal data”. Such transfers shall occur where they are necessary as part of the recruitment and/or related intermediary services we provide to or for you. By providing Personal Data you agree that your data may be transferred outside of the EEA in such circumstances.
We and/or the third parties to whom we may disclose your Personal Data may store your Personal Data on a server overseas. By providing Personal Data you agree your data may be transferred to servers located overseas.
We shall take reasonable steps to ensure your data is treated securely outside of the EEA.
You may contact us via email@example.com to exercise any of your rights under UK/EU data protection laws, specifically:
- To request access to a copy of your Personal Data;
- To withdraw your consent to us processing your Personal Data at any time;
- To request us to delete your Personal Data. If you would like us to delete the Personal Data we hold about you and specify why you would like us to delete your Personal Data – you agree that we may be unable to process your application or continue to provide any of our services to you;
- To request us to provide you with the Personal Data that we hold about you in a structured, commonly used, machine readable form, or ask for us to send such data to another data controller;
- To request us to rectify inaccurate information held about you further to such earlier data request by you (enclosing the evidence in support).
If you do not think that we have addressed your complaint satisfactorily then you may make a complaint about our data processing activities to a supervisory authority; for the UK this is the Information Commissioner’s Office at: www.ico.org.uk
You may contact us via firstname.lastname@example.org to exercise any of your rights under UK/EU data protection laws (or such other email address as may be displayed on the “Contact Us” section of any of the Websites from time to time); or write to our Data Protection Officer at Oxford Knight Ltd, 4th Floor, 33 Cannon Street, London, United Kingdom, EC4M 5SB.
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