CRINKLE RECRUITMENT – WEBSITE PRIVACY POLICY & COOKIES POLICY

 

Effective Date: 01 April 2019

Last Update: 01 April 2019

 

WEBSITE PRIVACY POLICY

Definitions

“We”, “Us” and “Our” means Crinkle Recruitment (part of The Schools HR Co-operative Limited.)  (“Crinkle Recruitment” or “Crinkle”) and should be construed accordingly.

“The Website” or “Our Website” refers to www.crinklerecruitment.com

“You” and “Your” refer to any individual accessing the website.

“User Account” refers to any account on our website that you may register, or be registered for, in order to use certain aspects of our Services.

“Candidate” and “Work-Seeker” refers to any individual interested in, or using our website and services to access our work finding services. 

“Hirer” “Recruiter” and “Recruiting Organisation” refers to any organisation using our permanent recruitment services

“The Services” or ‘Our Services” refers to any of our service provided for work-seekers, and/or hirers.

 

 

1. Introduction


www.crinklerecruitment.com is a website owned and operated by Crinkle Recruitment, part of The Schools HR Co-operative Limited (“SHRC”). Crinkle Recruitment is a trading name of The Schools HR Co-operative. You can learn more about The Schools HR Co-operative here.

Crinkle Recruitment is a recruitment agency, which provides recruitment services to hirers, and work-finding services to candidates. Our website acts as a medium that enables us to provide such services, in part or in totality. To provide certain services and/or certain aspect of our services. We must process personal data including sensitive personal data (referred to as ‘Special Categories of Personal Data’ for the purpose of this policy) – in doing so, Crinkle may act as data controller or data processer.

This privacy policy explains how we use the personal information we collect about you when using our website. The legal basis on which we rely to collect such information, how we process, share and store your details, and what your rights are in relation to managing or removing information held by us.

 

 

2. What personal information we collect from you


The categories of personal information that we collect from you, are determined by your use of our website and services, registration status. In relation to candidates/job-seekers, the recruiting organisations’ preferred recruitment process and their choice to use our consultative services.

The categories of information that we may collect from you include:

  • Personal information such as name, address, telephone numbers, email address, teacher reference number, national insurance number;
  • Special categories of personal data relating to recruitment monitoring includes characteristic information such as gender, age or age-range, ethnicity, religion, sexual orientation, disability status;
  • Special categories of personal data relating to criminal convictions such as non-protected convictions, cautions, reprimands or final warnings held by you, and additional information contained in any disclosure document you choose to upload to our website when submitting an online application form;
  • Suitability and eligibility information such as your declaration confirming that you are, or are not, disqualified from working with children or young people, your response(s) to application screening questions;
  • Education history and qualifications held including details of subject studied and/or trained in, training provider and/or educational establishment, dates of studies, grades achieved;
  • Career and employment history including the name, address and contact information of current, most recent and previous employment, job titles held, reasons for leaving, responsibilities held, salary information, notice period, details of statutory induction completion, teaching practice and experience;
  • Additional application information including personal statement, any additional information you volunteer to provide in support of any application submitted online or on any offline application form (e.g. recruiter’s own application form or alternative application form provided by us), availability for interviews;
  • Job preferences for Newly Qualified Teachers including the age range you wish to teach, preference for work in faith schools, dates of forthcoming university/college holidays in relation to availability for interviews;
  • Job email alert preferences such as whether you wish to receive job notifications by email, and the job category for which you would like to receive email notifications;
  • Job preferences and jobs of interest relating to saved job searches and job basket;
  • Vacancy source information such as where you saw a particular vacancy advertised;
  • Details of assessments such as responses to, and results of, any assessments we administer, and you complete, records relating to shortlisting/screening activity;
  • Application history including jobs you have applied for the associated recruiting organisation, your application status;
  • Device information such as information about the device you have used to access our website, this includes information such as the device type, operating system and hardware/ software version used, screen resolution (this information is anonymised and aggregated i.e. not personally identifiable when collected);
  • Network and usage information such as information about the network you use to access our website, and what content you interact with when you visit our website. This includes your IP address, the name of your internet service provider, language, time zone, country, city (this information is anonymised and aggregated i.e. not personally identifiable when collected).

 

 

3. How we collect your personal information


GENERAL USE OF OUR WEBSITE
This category of users includes any individual accessing our website, with or without a registered user account of any kind. We collect the following category of personal information when any user accesses our website, at any time and for any purpose:

  • Device information
  • Network and usage information

We collect such information from our website and through the use of cookies set by us and/or our third-party service providers. For full information our use of cookies can be found in our Cookies Policy.

CANDIDATES/JOB-SEEKERS
When you use any services that require basic registration, we collect the following categories of personal information (in addition to any category noted under ”General Use of Our Website”):

  • Personal information;
  • Job preferences and jobs of interest;
  • Suitability and eligibility information (applicable to the online application method only).

When you use any services that require full registration we collect the following additional categories of personal information (and any category noted under ”General Use of our Website”):

  • Special categories of personal data relating to recruitment monitoring;
  • Special categories of personal data relating to criminal convictions;
  • Education history and qualifications held;
  • Career and employment history;
  • Additional application information;
  • Job preferences for Newly Qualified Teachers;
  • Job email alert preferences;
  • Vacancy source information;
  • Application history.

We collect such information from our website, when you complete and save, or submit, any registration form, application profile, or application form.

The following additional category of personal information may be collected when you use any services that require full registration AND the recruiting organisation uses our Consultative Recruitment Services OR instructs us to administer any assessments on their behalf:

  • Details of assessments

We collect such information from our website when you submit an application form to an applicable vacancy, and/or through the IT system of a third-party service provider that we use for specific types of assessment.

DATA OBTAINED FROM A THIRD-PARTY

We may have obtained your personal information from a third party such as an online jobs board that we subscribe to, or a social media website such as LinkedIn. If we obtain your personal information from a third party, we will advise you of the source when we first communicate with you.

 

 

4. Why we collect your personal information and how we use it

 

GENERAL USE OF OUR WEBSITE
We collect anonymised statistical information on all users of our website, for the purpose of monitoring user interaction and behaviour on our website. Such information is collected and stored in the aggregate, and completely anonymised. We use this data for the following purposes:

  • to assist us in making improvements to our website and/or services
  • to generate internal reports about the use of our website and/or services
  • to provide our customers, advertisers, and suppliers, with statistical information

CANDIDATES/JOB-SEEKERS
We collect the categories of personal information described, for some or all the following purposes:

  • to send you essential communications regarding any changes to our services, policies, terms and conditions and complete any other administrative tasks essential to providing the services outlined in relevant Terms and Conditions;
  • to introduce and/or supply you to actual or potential hirers;
  • to provide you with the services outlined in our General Terms and Additional Terms for Candidates;
  • to respond to any queries, you raise in relation to the services we provide, or any account you hold with us;
  • where applicable, to provide you with relevant correspondence relating to the recruiting process for a vacancy you have applied for;
  • to send you email notifications regarding job vacancies, in accordance with the preferences you have expressed, and where you have provided us with your consent to do so;
  • to provide service to our recruiters (e.g. school employers) that enable them to complete the recruitment processes;
  • to assess your suitability and eligibility for job opportunities;
  • to detect, investigate and prevent activities that may violate our policies, and/or be in breach of any of our Terms and Conditions.

STATISTICAL INFORMATION

We collect anonymised statistical information on all users of our website, for the purpose of monitoring user interaction and behaviour on our website. Such information is collected and stored in the aggregate, and completely anonymised. We use this data for the following purposes: 

  • to assist us in making improvements to our website and/or services;
  • to generate internal reports about the use of our website and/or services;
  • to provide our customers, advertisers, and suppliers, with statistical information.

AUTOMATED DECISION-MAKING
In some instances, we use automated decision-making. Automated decision takes place when an electronic system uses personal information provided by you, to make a decision without human intervention. We will use automated decision-making under the following circumstances:

  • When you attempt to apply for a vacancy which uses our online application form as the preferred application method. In this case, you will be presented with a web page titled ‘Screening Questions’ and required to provide a ‘Yes’ or ‘No’ response to an eligibility question, and where applicable, suitability question(s) relating to specific job experience and/or qualifications that are essential requirements for the vacancy in question.

When we make an automated decision about you, you have the right to contest the decision, express your point of view, and to request a human review of any automated decision we make. You can exercise this right by contacting us.

 

 

5. The lawful basis on which we process this information


We rely on one or more of the following grounds to legally collect and process your personal information:

  • Processing is necessary to fulfil a contract – We will process your personal information, where necessary, for the performance of the contract which we have with you
  • You have provided consent – We will process your personal information, where you have consented to us doing so. For example, we rely on your consent to send you email notifications that are not essential to the provision of our services. You have the right to withdraw this consent at any time. Where consent is the only legal basis for processing certain aspects of your personal information, we will cease to process that personal information if you withdraw your consent. Any such withdrawal of consent will not affect the lawfulness of any prior use of that personal information, before the date of withdrawal.
  • It is in our legitimate interests and these interests do not override your data protection rights - We may process certain aspects of your personal information, when it is in our legitimate interests to do so, and where these interests do not override your data protection rights. Our Legitimate Interests include:
    • Internal analysis and statistical reporting (of anonymised and aggregated data) based on the services we provide and our performance of those services

 

 

6. How we store your information and how long we retain it


We take all reasonable steps to protect your personal information from unauthorised access, accidental loss, destruction and/or damage.

All personal information that we collect from you is, where possible, stored and processed inside the European Union (EU). There are certain circumstances, which require us to transfer certain aspects of your personal data outside of the EU. In such circumstances, we take all reasonable steps to ensure that any personal information transferred, is not excessive (we will only transfer information that is essential for the provision of service), is treated securely, and in accordance with this privacy policy and the data protection legislation.

TRANSFER OF PERSONAL DATA OUTSIDE OF THE EU
We use third-party service providers outside of the EU for the following aspects of our services:

  • Email communications
  • Administrative notifications associated with our services and/or the recruitment process (e.g. automated email notifications from the website)
  • Analytics information relating to our website traffic and usage
  • Optimisation of our website’s performance

Countries outside of the EU may not have the same level and standard of data protection legislation that is applicable to countries within the EU. We will only transfer your personal information to non-EU based third-party service providers where:

  • The third-party service provider is in a non-EU country that is recognised by the European Commission as a country that provides an adequate level of protection for personal data; or,
  • The third-party service provider is based in the United States (U.S.) and can certify that it complies with the EU-U.S. Privacy Shield Framework, designed by the U.S. Department of Commerce and the European Commission, to ensure the transference of personal data, complies with data protection requirements.

RETENTION OF PERSONAL INFORMATION
We will only keep your personal information for as long as we reasonably require it to provide our services. Our data retention periods are determined by the type of personal information we hold, and why we hold this information. Any personal information we retain is held in accordance with the principles of data protection legislation, other relevant applicable legislation, and operational retention needs.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003 (“Conduct Regulations”), require us to keep work-seeker records for a specified period of time.

Where we have obtained your consent to process your personal information as described in sections 2, 3 and 4 of this Privacy Policy. We will retain the personal information that you provide to us for at least twelve (12) months from (a) the date of creation or (b) after the date on which we last provide you with work-finding services. This retention period enables us to comply with the requirements set out in the Conduct Regulations. Upon expiry of this retention period we will no longer process or retain your personal information.

CANDIDATES/JOB SEEKERS
User Account and Application Profile – Retained until our provision of service ceases or you request deletion of your account.

Personal information that you provide to us for the purpose of holding a user account and/or application profile, will be retained until it is no longer necessary to provide our services. Or until you request that we delete your account, whichever occurs first.

Application Forms, Recruitment Related Notifications and Correspondence – Retained for a period of twelve (12) months.

Personal information relating to application forms you have submitted, and/or any recruitment related notifications and correspondence, processed by us on behalf of a recruiting organisation, are retained by us for twelve (12) months from date of submission (application forms) or the date sent (notification/correspondence).

DATA OBTAINED FROM A THIRD-PARTY
If we have obtained your personal information from a third party and you notify us that you do not wish us to provide you with our services, we will remove your personal data from our internal systems. If you proceed to register on our website and use our services your data will be retained in accordance with the retention period described above, or in the case of basic registration for a user account, in accordance with the retention policy detailed in Section 6.

 

 

7. Who we share your information with and why we share it


Personal information provided by you, is not shared with third parties unless it is necessary for us to do so, For the purpose of the performance  for our contract and services. , Then we are permitted to do so with your consent or are required to do so by law,  in line with our policies. In such cases, we may make personal information available to:

RECRUITING ORGANISATIONS
In the course of our business to assist you in job seeking related activities, your personal information is transferred to recruiting organisations (e.g. employing schools) whenever you apply for a vacancy; related to a specific organisation, through our website and/or services. Such information comprises all personal data that you have provided to us, on any application form you submit.

It is important to note that, when you agree to use our services. In order to carry out our contractual obligations under these circumstances, the personal information you supply, is transferred to the recruiter. Who then becomes the data controller for that information. This means the recruiting organisation becomes responsible for your personal data and will determine how it is processed, in line with that organisation’s privacy and data protection policies. Therefore, our privacy policy no longer governs how the information held by that organisation is controlled. This applies to all information contained in any application form you submit including, ‘Special Categories of Personal Data relating to Criminal Convictions’ but excluding ‘Special Categories of Personal Data relating to Recruitment Monitoring’.

Such information comprises of the following categories of personal information:
Personal information

  • Special categories of personal data relating to criminal convictions and suitability to work with children;
  • Education history and qualifications held;
  • Career and employment history;
  • Additional application information;
  • Job preferences;
  • School preferences and schools of interest (relating specifically to the hirer in question e.g. to feedback your interest in job opportunities with a specific hirer in line with your preferences)
  • Details of assessments;
  • Details relating to specific job opportunities (relating specifically to the hirer in question e.g. to provide your feedback following an interview or your response to an offer of employment).

Personal information relating to ’Special Categories of Personal Data relating to Recruitment Monitoring’ if shared, is provided in aggregated form and completely anonymised (e.g. not individually identifiable).

The following category of personal information are never shared with recruiting organisations:

  • Application history (related to vacancies that are not associated with the recruiter’s own organisation)

 
OUR SERVICE PROVIDERS
Certain aspects of personal information you provide to us, may be shared with third party providers. Who assist us in carrying out business activities and enable us to provide and deliver those services. Our third-party service providers include:

  • IT Systems and Website Support Service Providers;
  • Email Delivery Service Providers (including those outside the EU who comply with the EU-U.S. Privacy Shield Framework);
  • Data Storage and Hosting Service Providers;
  • Recruitment Assessment Providers.

OTHER CIRCUMSTANCES
In certain circumstances, we may disclose your personal information to other third parties such as governmental authorities, law enforcement agencies and data protection regulators. If we are required to do so by law.

 

 

8. What rights you have for accessing and removing this information


Under data protection legislation, you have certain rights relating to the information we hold on you.

ACCESSING YOUR INFORMATION
You have the right to request access to information about you that we hold. To request such information, you will need to make a Subject Access Request (SAR). All SARs are processed in accordance with our Subject Access Request Policy.

RECTIFYING YOUR INFORMATION
You have the right to amend or delete any information that we hold on you that you believe is inaccurate. You can rectify information held in your Application Profile / User Account by Signing In or by contacting us.

If you believe any other information we hold on you is inaccurate e.g. an application form you have submitted, you will need to contact us.

OBJECT TO YOUR INFORMATION BEING PROCESSED FOR DIRECT MARKETING PURPOSES
You have the right to withdraw your consent to receive communications from us relating to non-essential services. This currently relates to the following aspect of services offered by us:

  • Job Notifications by Email;
  • SMS notifications from Crinkle Recruitment with general job notifications, advice, information, and tips.

If you have consented to receiving these communications. You can withdraw your consent at any time by Signing In to your account and amending your Job Email Alert preferences or by contacting us. 

DELETING YOUR INFORMATION & WITHDRAWING CONSENT
You have the right to close any account you hold with us, at any time and have us delete all of your personal information. To request closure of your account and/or removal of all personal information we hold on you, please contact us

If you wish to withdraw your consent to Crinkle Recruitment processing your personal information for the purpose of providing you with work-finding services, you have the right to do so at any time.

If you wish to exercise your right to withdraw consent, and/or to have your personal information deleted please contact us as described below. Please note, there may be circumstances where we will need to process or retain some or all of your personal information due to legal or official reasons. Should the occasion arise, we will inform you and  will restrict the data that we continue to process or retain, to only what is necessary for the purpose of meeting those specific reasons.
 
REPORTING CONCERNS
If you have a concern about the way we are collecting or using your personal data. Kindly, raise your concern with us in the first instance. Alternatively, you can also contact the Information Commissioner’s Office (ICO) at: https://ico.org.uk/concerns/

FURTHER INFORMATION AND HOW TO CONTACT US
If you would like to discuss anything in this privacy notice, or about the information we hold on you. Please contact our Data Protection Officer (DPO):

  • By email: dataprotection@schoolshr.net
  • In writing at: Data Protection Officer, The Schools HR Co-operative Ltd, Unit 1 Britannia Court, The Green, West Drayton, Middlesex, UB7 7PN

 

 

9. Other websites and other data controllers


This privacy policy applies to this website only. When you visit other websites and/or provide your data to other data controllers you should review their own privacy policy.

 

 

10. Changes to this Privacy Policy

 

We review this privacy policy regularly and reserve the right to make changes at any time. To reflect changes to the business and legal requirements. We place updates on this webpage, please refer to the ‘Last Update’ date at the top of this Privacy Policy

 

 

COOKIES POLICY

 

1. What Are Cookies


It is common practice with almost all professional websites uses cookies. Which are tiny files that are downloaded to your computer to improve your browsing experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored, however this may downgrade or 'break' certain elements of the website functionality.

For more general information on cookies see http://www.allaboutcookies.org/

 

2. How We Use Cookies


We use two types of cookies on our website: cookies we set (www.crinklerecruitment.com) and cookies set by third parties (i.e. other website and services).

We set our own cookies to help you stay signed in to your account while using the services we provide on our website, and to tailor information to your site preferences.

We use cookies set by third party providers, to optimise the performance of our website and better understand how the features and functions of our site are used. So that we can improve our services, for a better customer experience.

As in most cases, there are no industry standard options for disabling all cookies without completely disabling the functionality and features they add to the website. If you are not sure whether you need them or not.It is recommended that you leave on all cookies, to aid the provision of a service that you may wish to use.

 

3. Disabling Cookies


You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this).

Please be aware that disabling cookies will affect the functionality of this website, and usually will result in disabling certain functionality and features too. If you disable cookies on this website, the following Key functions and features will not be useable:

  • Registering for an account on our website
  • Signing in to an account on our website
  • Using your account to register for work-finding services on our website

 

4. Cookies Set by Crinkle Recruitment


Account related cookies
If you create an account with us we will then use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out. However, in some cases they may remain afterwards to remember your site preferences.

Login related cookies
We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page on our website. These cookies are typically removed or erased when you log out to ensure that you can only access restricted features and areas when logged in.

Forms related cookies
When you submit data to us through a form, such as those found on contact pages, cookies may be set to remember your user details for future correspondence.

Site preferences cookies
In order to provide you with a great experience on this website, we will provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page that is affected by your preferences.

 

5. Third Party Cookies


In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

This website uses Google Analytics, a web analytics service provided by Google LLC (“Google”). Google Analytics is one of the most widespread and trusted analytics solutions on the web helping us to understand how you use the site, and ways that we can improve your experience.

The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google undertakes not to associate your IP address with any other data held by Google.

For further information on how google uses data collected from its partners site please follow this link: https://policies.google.com/privacy/partners?hl=en-GB&gl=uk

You can prevent the setting of third party cookies by adjusting the settings on your browser (see your browser Help for how to do this). Alternatively, to opt out of Google Analytics please go to the following link: https://tools.google.com/dlpage/gaoptout

By using this website, you consent to the processing of data about you by Google, in the manner and for the purposes set out above.

If you choose to disable third party cookies, this may also affect your ability to access the full features and functions of this website.

 

6. List of Cookies


Cookie Name Expiration Time Description
_ga 2 years Used by Google Analytics to distinguish users.
_gid 24 hour Used by Google Analytics to distinguish users.
_gat… 1 minute Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.
ASP.NET_SessionId expire at the end of the session When a user connects to an ASP.NET application, a unique session ID will be affiliated with the user.

 

7. Cookies on Other Websites


Our website may contain links to other websites which are owned and controlled by a third party. These external websites may use cookies not set or managed by us, and different from those we use on our website.

 

8. More Information


If you would like more information, then please contact us.