Privacy Policy for Môrwell Talent Solutions Ltd
Who are we?
We are a recruitment business (company number 15745422) and we provide work-finding services to our clients and work-seekers. As a company, in order to provide these services, we must process personal data (including sensitive personal data). In doing so, the company acts as a data controller.
You may give your personal details to the company directly, such as on an application or registration form or via our website. Or we may collect data from another source, such as a job board onto which you have uploaded your CV. The company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you, we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws.
What does this Policy cover?
We take your data seriously at Môrwell Talent Solutions. This policy:
- sets out the types of personal data that we collect about you
- explains how and why we collect and use your personal data
- explains how long we keep your personal data for
- explains when, why and with who we will share your personal data;
- sets out the legal basis we have for using your personal data;
- explains the effect of refusing to provide the personal data requested;
- explains the different rights and choices you have when it comes to your personal data; and
- explains how we may contact you and how you can contact us.
What information might we collect?
Candidates; We collect and use only the information necessary to be able to find the best available opportunities and any further information needed to assess your eligibility through the different stages of recruitment. This information includes CVs, identification documents, educational records, work history, employment and references and financial information.
We may also collect sensitive personal data about you, related to your health, diversity information or details of any criminal convictions. We only collect sensitive personal data from you, and further process this data, only where you have given your explicit prior consent.
Clients; We collect and use only the information necessary to provide you, or people in your organisation with services such as finding the best available candidates for your opportunities.
Other data subjects; We collect and use only the information necessary to be able to contact you and pay you for the services you provide.
From where do we collect personal data about you?
The following are the different sources from where we may collect data about you:
- Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages, or during the course of our work with you to ensure that our relationship runs efficiently.
- From an agent/third party acting on your behalf. e.g. A Contractor’s Limited Company.
- Through publicly available sources. For example;
- Job Boards
- By Reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
Where we collect your information through publicly available sources as set out above, we may do this with the aid of software programmes. These programmes are given parameters on the requirements of a role and search through publicly available sources to find such candidates. These programmes are designed to only output information on candidates that meet the search criteria. The parameters of this program are restricted to only searching for candidate information from public sites where there is a reasonable expectation that such information may be collected and further processed by job recruiters for the purpose of sourcing candidates for different job roles.
How long do we keep your personal data for?
We will only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, we may retain some of your information after you cease to use our services, if we believe in good faith that it is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- (potential) disputes;
- guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
Who do we share your personal data with?
Candidates; We share your personal data with the client who has a position to fill, in order to determine with the client whether you are a good fit for the available position.
We may also conduct checks on you to verify the information you have provided and where we do this we share your information with our appointed background checking company.
Unless you specify otherwise we may share your data with any of our associated third parties – for example our payroll and pension providers – to provide you with the best possible service.
Clients; We share your data with candidates during the course of providing recruitment services to you, and with third parties as part of our contractual relationship.
Suppliers; We share your data third parties as part of our contractual relationship.
What legal basis do we have for using your information?
For prospective candidates, contractors, referees and clients, our processing is necessary for our legitimate interests. We need this information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees, and suppliers.
If you are interviewed and submitted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
Where we need your consent for some activities such as contacting candidates about other recruitment-related services we will ask for it. We rely on soft opt-in consent for these activities where you have previously engaged with us by submitting a CV, applying for a job, or registering on our website. This means we take you consent as given unless or until you opt-out. For other types of e-marketing we require your explicit consent.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.
Do we make automated decisions concerning you?
We may make automated decisions about you during the assessment stage of the recruitment process. We put assessment candidates through a structured screening process to assess whether each candidate meets the specific criteria for a particular position. These assessments may be fully automated e.g. online pre-screening tests. As these assessments may result in a candidate being deemed not suitable for a position by means of a solely automated assessment, we only undertake this activity with the candidate’s explicit consent. We also carry out personality profiling on candidates with the candidate’s consent.
Legitimate interests
For us at Môrwell Talent Solutions Ltd to carry out work on your behalf in an effective manner, it is reasonable for us to need to store certain elements of your personal data. As a Recruitment Consultancy who submit candidates to permanent and contract assignments, the exchange of candidate and client data is essential.
Having a database of candidates and clients with certain elements of personal data is needed to support individual career aspirations and to fulfil client’s resourcing requirements. We also feel it’s reasonable for us to hold data on prospective candidates and clients in order for us to grow our business.
If you are looking for new employment or have uploaded your CV or similar information to a job board or professional networking site, we’d reasonably assume that you are happy for us to collect this data and to contact you to support you in that objective. Prior to us sending any of your data to our clients or any other trusted party, we will first seek your consent.
Potential employers may want to confirm your qualifications or references at some point in the process, so again we feel it is necessary for us to hold your data to fulfil these obligations and to help you land that dream job. Providing you with tailored job alerts also requires us to process your data to ensure the content is appropriate to your needs. And we may also need to use your data for internal administrative activities, like payroll and invoicing.
Data Retention
Any personal data held is stored on our secure recruitment database which is password protected and accessible only by our professional and qualified consultants for the purposes of finding you work finding services or supporting our clients to identify suitable applicants for the vacancies which we are supporting them with. We also have a confidential waste facility in place to safely discard any printed CVs we are working with.
The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.
We typically support candidates throughout their careers and so may often hold their data for lengthy periods. We do, however, proactively communicate with everyone whom we hold data for once per year to remind them of our privacy policy, remind them of their data rights and ensure they are still happy for us to continue to hold their data.
If you wish for your data to be permanently removed from our database, please email info@morwelltalentsolutions.co.uk and your request will be actioned within 2 working days.
Your rights
Please be aware that you have the following data protection rights. You have the right:
- to be informed about the personal data the company processes on you;
- of access to the personal data the company processes on you;
- to rectification of your personal data;
- to erasure of your personal data in certain circumstances;
- to restrict processing of your personal data;
- to data portability in certain circumstances;
- to object to the processing of your personal data that was based on a public
- or legitimate interest;
- not to be subjected to automated decision making and profiling; and
- to withdraw consent at any time.
Where you have consented to the company processing your personal data, you have the right to withdraw that consent at any time by contacting us via info@morwelltalentsolutions.co.uk. Please note that if you withdraw your consent to further processing, that will not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
There may be circumstances where the company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.
If you believe that any of your data that the company processes is incorrect or incomplete, please contact us using the email address above and we will take reasonable steps to check its accuracy and correct it where necessary. You can also contact us using the above details if you want us to restrict the type or amount of data that we process for you, access your personal data or exercise any of the other rights listed above.
Cookies
We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. 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.
We use Google Analytics to analyse our website. This uses a small cookie that allows the site owner to check which pages are the most popular on the site and so provide more site content that is popular to users. It contains no personal or private data at all and is used on millions of websites worldwide.
If you wish to opt-out of Google Analytics data collection you can do so by using the
Google Analytics Opt-out Browser Add-on.
To learn more about cookies, you may wish to visit:
www.allaboutcookies.org, www.youronlinechoices.eu or www.google.com/policies/technologies/cookies/
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 you remove cookies from your browser.
Links to external websites
The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site, we encourage you to read the privacy statements of each website that collects personally identifiable information. This privacy statement applies solely to information collected by our Company website.
Data security
The Company takes every precaution to protect our users’ information. Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information via our password protected recruitment database.
The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.
If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered.
Changes to this privacy statement
We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.
Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it, please write to us via info@morwelltalentsolutions.co.uk
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
If you wish for your data to be permanently removed from our database, please email info@morwelltalentsolutions.co.uk and your request will be actioned within 2 working days.
