Privacy Policy.

Creation Recruitment is committed to providing excellent customer care.

That means we need to record and store some of your personal information to either help you find a great job or hire a great person. So this policy outlines what data we collect, how we use it and what your rights are.

We’ve updated our Privacy Policy to comply with the requirements of new European data protection laws (specifically the General Data Protection Regulation or GDPR). Privacy Policies are not riveting reading so we’ve tried to make it straightforward, but some legal terms and wording don’t like to be simple. As an example the reason we need to use your personal data is our “Lawful basis for processing”.

Contents

  • Introduction
  • What personal information do we collect about you?
  • How and when do we collect your personal information?
  • How do we use your personal information?
  • Disclosure of your personal information
  • International Transfers
  • How long do we keep your information?
  • Security
  • What are your rights?
  • Cookie Policy

Introduction

This privacy policy governs the collection, storage and use of personal information collected by Creation Recruitment Limited, registered company number 05933384 (collectively referred to as “Creation Recruitment”, “we”, “us” or “our” in this privacy policy).

This policy does not cover any use of your personal information by:

  • An organisation that employs you or hires your services.
  • An organisation you are introduced to via us with the intention of employing you or hiring your services.
  • Any organisation involved in the supply of your services via us such as an umbrella company, who we provide your personal information to as part of the recruitment process.

In all these cases, the use of your personal information will be governed by that organisation’s own privacy policy. 

Our service is obviously not intended for children and we do not knowingly collect information relating to children.

Changes to our Privacy Policy

We may need to change the terms of this policy from time to time or as required by the law. Any changes will be posted on this page.

This version was last updated on 16th of May 2018

It is important that the personal information we hold about you is accurate, so please keep us informed if your personal information changes during your relationship with us.

What personal information do we collect about you?

If you are looking for a digital job, now or in future:

We will usually collect the following information from or about you:

  • Name
  • Address
  • Phone and email details
  • Current and previous employment details, including job title and employer
  • Professional certifications relevant to the job or jobs you are looking for
  • Education and qualifications
  • Professional skills
  • Salary or consultancy rate range
  • Right to work status and citizenship
  • Any information you include in your CV or an application form
  • Relevant information which has been published or made available on a social media profile or job board (whether by you or a third party), or in any news media
  • References from previous employers
  • Email communications and attachments, such as portfolios which you send to us
  • A copy of your passport details including your passport photograph
  • Any other information either relevant or required by law to enable us to provide our services

If you get offered a job via us:

If you have secured an offer of employment via us, we may also collect the following:

  • The results of any right to work checks we are required to carry out by the hiring organisation
  • The results of pre-employment screening or vetting checks we are required to undertake in relation to you (such as Disclosure and Barring checks, credit checks and information you provide relating to current or spent criminal convictions) 

If you are a Consultant working for an organisation on an interim or contract basis via us, we will also collect the following information:

  • Your bank details
  • Details of your umbrella company or personal service company
  • The contract for services we hold with your umbrella company or personal service company relating to the work you do for our client organisation, including timesheet information and rates charged relating to the work you perform under that contract

You can update your CV or personal information at any time by:
Emailing one of our Consultants or info@creationrecruitment.co.uk
Calling one of our Consultants on 01179 298 243.

If you are looking for a new digital employee or consultant, now or in the future:

We will usually collect the following information from or about you:

  • Name 
  • Work address
  • Work phone and email details
  • Your title, role and responsibilities within your organisation
  • Any opinion or feedback you share with us regarding a candidate or consultant
  • Details of any questions you ask us regarding our services
  • Details about your recruitment requirements you share with us
  • Any other information relevant to enable us to provide our services

If you are a providing a reference for someone:

If you are a referee. We collect your basic work contact details; name, title, office address, email and telephone number. So we can contact you for a reference for a candidate or consultant.

How and when do we collect your personal information?

Direct interactions

You may give us your information by contacting us. Usually by phone, email or by meeting us.

Automated technologies or interactions

When you use our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We do this by using cookies and other similar technologies.

Third parties and publicly available sources

We may receive personal data about you from various third parties and public sources such as:

  • Google Analytics
  • Companies House
  • Social networking sites
  • Job Boards

If you are looking for a digital job, now or in future:

We will collect your personal information when:

  • You contact us (usually by phone, email or by meeting us)
  • We contact you as a result of a personal recommendation
  • We download details uploaded by you onto a job board, LinkedIn or other social networking site
  • You respond to an advert posted by us via a job board, LinkedIn or other social networking site
  • You access and browse our website and submit personal information to us
  • We provide Services to you or we contact you with a view to providing Services to you

If you are looking for a new digital employee or consultant, now or in future:

We will collect your personal information when:

  • You contact us about providing our services to you either now or in the future (usually by phone, email or by meeting us)
  • We contact you with a view to providing Services to you
  • We currently provide our services to your organisation
  • We agree terms to provide our services to your organisation

If you are a providing a reference for someone:

We will collect your personal information usually by phone, email or when we meet you.

Third party websites

Our 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 information about you.

We cannot be responsible for personal information that third parties collect 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.

Anonymous information

We collect, use and share aggregated data about the visitors to our website for the purposes of reporting on, and improving the website. For example, to calculate the percentage of users accessing a specific website feature. However, we only collect anonymised details for these purposes which do not identify you.

If in future we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we will treat the combined data as personal data, which will be treated in accordance with this privacy policy.

Our cookie policy

We may obtain information about your general internet usage by using a cookie file which contains information that’s transferred to your browser or your computer’s hard drive.

They help us to improve our website and deliver a more relevant and better service to you.

Some of the cookies we use are essential for the website to operate.

If you register with us or if you continue to use our website, you agree to our use of cookies.
Unless you’ve adjusted your browser setting so it blocks cookies, our system will issue cookies as soon you visit our website.

You can block cookies by changing the setting on your browser which allows you to block all or some cookies. However, if you block all cookies (including essential cookies) in your settings, you may not be to access all or parts of our website and others.

Google Analytics

Google Analytics uses traffic log cookies to gain information about the use made of pages on our website.

We use the information from these cookies to generate reports that help us analyse things like which pages of our website visitors are using the most.

You can find out more about Google’s privacy policy here: http://www.google.com/privacy.html

You can opt out of the process of collecting traffic log data here: http://tools.google.com/dlpage/gaoptout

You can find more information about cookies and how to control their use by visiting: www.allaboutcookies.org or www.youronlinechoices.eu

Log Files

We automatically collect information about your computer including, where available, your IP address, operating system and browser type, for system administration. This is statistical data about your browsing actions and patterns, and does not identify you as an individual.

How do we use your personal information?

If you are looking for a digital job, now or in future:

We use your personal information:

  • To match you to jobs and assignments which meet your requirements
  • To contact you (by email, text or phone) about the jobs and assignments we believe you’ll be interested in
  • To enable you to submit your CV to us either for general applications, or to apply for specific jobs we are helping organisations to hire people for
  • To enable us to send your CV and any other relevant information to organisations who use us to help them hire people
We always have, and always will obtain your verbal or written consent before providing your personal information to a client organisation.

We also use your personal information:

  • To provide recruitment-related support
  • To carry out services that we, you or client organisations have asked for such as references, qualification and criminal references checking, verification of details you’ve provided and psychometric or skills tests
  • To enter into contracts necessary for your services to be supplied to a client organisation
  • To develop our relevant database of digital professionals and organisations who hire them, so we can help you find relevant work opportunities, and help our client organisations hire the people they want.
  • To let you know about any of our networking or career-development events such as Mobile Monday
  • For internal record keeping purposes

Because this storage and use of your personal information allows you to be contacted about jobs we think will be of interest to you, now or in the future, we don’t believe it will unduly prejudice your rights or freedoms.

We will also store and use your personal information in order to comply with our relevant legal obligations:

  • Verification of your identity to comply with The Conduct of Employment Agencies and Employment Businesses Regulations 2003
  • Right to work checks to comply with relevant immigration legislation

If our client organisations carry out further relevant background checks, we will be acting on behalf of them, so the handling of your personal information will be governed by their own privacy policy. 

If you get offered a contract or consultancy job via us:

We use your personal information:

  • To complete and administer contracts with your personal service company, umbrella company or consultancy company and for processing payments to that company for the services you or your consultancy have performed for our client organisation.
  • For you to do what a contract requires you to, when you are a party (i.e. your contract with the company you work with to provide assignment/consultancy services)
  • To take steps prior to you entering into a contract, including contracts we enter into with the client organisation relating to the provision of your services or consultancy services.
  • If our client organisation requires us to collect, store and use your health data and/or a Disclosure and Barring Check, then we’ll seek your consent to processing the data on their behalf. You can withdraw your consent at any stage but it may stop us from being able to deliver our recruitment service to you.

Because this storage and use of your personal information allows us to provide services to you and our client organisation, it will be for our legitimate interests, so we don’t believe it will unduly prejudice your rights or freedoms.

If you are looking for a new digital employee or consultant, now or in future:

We collect, store and use your name and work information for our legitimate interests, so that we can:

  • Send you the details of candidates and consultants when you have asked us to do so
  • Contact you about our services
  • Maintain our business relationship with you 

This allows you to be contacted to receive and administer any of our services which are relevant to you or your organisation. 

We have never, and will never, send you details of someone unless you’ve requested our services.

If you are a personal service or umbrella company, supplying resourcing services:

We use your personal information:

  • To contact you to provide details of current and future assignments, relevant timesheet information and payment details

Because your purpose is to provide assignment/consultancy services, we don’t believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.

If you use our website:

We use your personal information:

  • To make the website available to you
  • To provide any services you request

Change of purpose:

We will only use your personal data for the purposes we collected it for, unless we reasonably consider we need to use it for another reason that’s compatible with the original purpose.

The reasons include:

  • If we’re asked to prove our compliance with applicable laws 
  • If we get an enquiry from HMRC or the Employment Agencies Standards Inspectorate
  • To detect and prevent fraud
  • To keep our website and IT systems secure
  • To make sure our systems, processes and procedures are efficient
  • To analyse and enhance any information we collect 
  • To analysing our marketing and advertising campaigns
  • If we’re requested to disclose your personal information to regulatory bodies

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.

In those circumstances, we believe we have a legitimate interest in handling your personal information, and do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.

Opting out of marketing:

You can request to unsubscribe from our job alerts or marketing material at any time.
This doesn’t apply if you’ve used our service.

We will not share your personal data with any third party organisation for marketing purposes. 

Disclosure of your personal information

We will disclose your personal information under the following circumstances:

  • To perform our recruitment services.
  • We will share your personal information with client organisations when you have given us your consent to do so.
  • When you tell us you’re supplying your services via us to a client organisation through an umbrella company, personal service company or consultancy company.
  • When our client organisation uses a Recruitment Process Outsourcer (RPO) or a Managed Service Provider (MSP).

We’ll share your information with RPO’s and MSP’s only with your consent. They will have their own privacy policy.

  • When we’re required to comply with legal process, respond to court orders, or to establish or exercise our legal rights or defend against legal claims.
  • In order to investigate, prevent or take action against illegal activity, potential threats to the safety of a person, violations of our terms of use, or as otherwise required by law.
  • When we use a third-party service company to help and support us provide our services.

They include:

    • IT support services
    • Software Providers
    • Credit referencing
    • Vetting and screening services
    • Payment processors

All our third parties must respect the security of your personal data and treat it in accordance with the law.

International Transfers

We use Adobe Sign as an external third party supplier, who are based outside the European Economic Area (EEA) in the USA so their processing of your personal information will involve a transfer of data outside the EEA.

They are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the USA.

If we use other third party suppliers in future, we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. 

How long do we keep your information?

 

We will retain your personal information for a period of 24 months from the date when we last contacted you. 

We will only retain your personal information to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will then delete it except where we need to comply with our legal obligations, resolve disputes, or to support a claim or defence in court.

Security

We will take all reasonable and appropriate measures to protect your personal information from misuse, loss, or unauthorised access.

We have a number of technical and organisational measures in place, including measures to deal with a suspected data breach.

If you suspect any misuse, loss of or unauthorised access to your personal information please let us know straight away.

What are your rights?

You have the right to:

Request access to your personal information

Known as a “data subject access request”. This enables you to receive a copy of the personal information we hold about you and to check we are processing it lawfully.

Request correction of your personal information we hold about you

This enables you to correct any incomplete or inaccurate information we hold about you, although we may need to verify the accuracy of the new information you provide to us.

Request erasure of your personal information

This enables you to ask us to delete or remove your personal information where there’s no good reason for us to continue processing it.

You also have the right to ask us to delete or remove your personal information where you’ve successfully exercised your right to object to processing (see below), if we’ve processed your information unlawfully or where we’re required to erase your personal information to comply with local law.

We may not always be able to comply with your request of erasure for specific legal reasons, but we’ll notify you if applicable, when you make the request.

Object to processing of your personal information

This enables you to object to us processing your information because you feel it impacts on your fundamental rights and freedoms.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms. An example is the processing of your information for the establishment, exercise or defence of a legal claim.

You also have the right to object where we are processing your personal information for marketing purposes.

Request restriction of processing of your personal information

This enables you to ask us to suspend the processing of your personal information for the following reasons:

  • You want us to establish the accuracy of your information
  • If our use of your information is unlawful but you don’t want us to delete it
  • If you need us to keep the information for you to establish, exercise or defend a legal claim
  • If you’ve objected to our use of your information but we need to verify if we have legitimate grounds to use it.

Request the transfer of your personal information to a third party

We’ll provide you, or a third party you’ve chosen, your personal data in a structured, commonly used, machine-readable format.

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

This won’t 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 services to you. We’ll advise you if that’s the case.

Fees

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 unfounded, repetitive or excessive. We may also 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 information (or to exercise any of your other rights).

This is a security measure to ensure that personal information isn’t disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information about your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month.

Occasionally it may take us longer than a month if your request is particularly complex or you’ve made a number of requests. In this case, we will notify you and keep you updated.

Please help us achieve the highest standards

We want to achieve the highest standards when we collect and use your personal information.

We take any complaints we receive about this very seriously. We encourage you to let us know if you think our collection or use of information is unfair, misleading or inappropriate.

We would also welcome any suggestions you may have to improve what we do.

Contact us

We would also welcome any suggestions you may have to improve what we do.

If you wish to exercise any of your rights, make a complaint or ask a question please contact us

Further information

For further information on your rights and GDPR, please visit the website of the UK supervisory authority; the Information Commissioner’s Office (ICO): https://ico.org.uk/