CRINKLE RECRUITMENT – WORK-SEEKER PRIVACY POLICY

 

Effective Date: 01 November 2017

Last Update: 15 October 2018

 

WORK-SEEKER 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. Crinkle Recruitment must process personal data including sensitive personal data (referred to as ‘special categories of data’ for the purpose of this work-seeker privacy policy) – in doing so, we act as a data controller.

You may give your personal details to us directly, such as on a CV or registration form or via our website, or we may collect them from another source such as a jobs board. This work-seeker privacy policy explains how we use the personal information we collect about you when you use our website and services, the legal basis on which we rely to collect such information, how we process, share and store your information, and what your rights are in relation to managing or removing information held by us. For the purposes of providing you with recruitment services or work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of this work-seeker privacy policy, and where applicable, our General Privacy Policy.

 

 

2. What personal information we collect from you


The categories of personal information that we collect from you, when you visit, or complete a basic registration on our website include:

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, information relating to checks conducted to verify identity and eligibility to work in the UK, physical attributes provided on photographs
  • Special categories of personal data relating to recruitment monitoring including characteristics information such as gender, age or age-range, ethnicity, religion, sexual orientation, disability status
  • Special categories of personal data relating to criminal convictions and suitability to work with children such as your declaration confirming that you are, or are not, disqualified from working with children or young people, prohibited from teaching, 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 your registration
  • 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, teaching practice and experience, references
  • Additional application/registration information including personal statementor cover letter, gaps in employment, date of application/registration, any additional information you volunteer to provide in support of your application/registration
  • Job preferences including the age range you wish to teach, preferred type of school, preferred location
  • School preferences and schools of interest relating to schools you save, shortlist and/or identify as not for you
  • How you heard about us such as where you saw our services advertised
  • Details of assessments such as responses to, and results of, any assessments we administer and you complete
  • Details relating to specific job opportunities such as hirers to whom you have been introduced (e.g. job opportunities you have been put forward for, attended an interview for, and/or have been offered)
  • 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


When you use our website and services to access our work finding services. We will collect and process the following categories of personal information:

  • Personal information
  • Special categories of personal data relating to recruitment monitoring
  • 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/registration information
  • Job preferences
  • School preferences and schools of interest
  • How you heard about us
  • Details of assessments
  • Details relating to specific job opportunities

We collect such information from our website, when you complete and save, or submit, any user profile and CV, and when you use certain functionality on our website to identify hirers (e.g. school employers) and vacancies of interest.

Please note: Our General Privacy Policy is also applicable each time you visit our website and we collect the following additional categories of personal information (in addition to any category noted above):

  • Device information
  • Network and usage information

For further information, please see our General Privacy Policy.

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

 

We collect the categories of personal information described in the previous section, 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
  • provide you with the services work-finding services as outlined in our Additional Terms and Conditions (for Candidate’s)
  • to respond to any queries you raise in relation to the work-finding services we provide, or any account you hold with us
  • to contact you about job opportunities relating to your preferences, and put you forward for such opportunities
  • to assess your suitability and eligibility for job opportunities
  • to provide services to hirers (e.g. school employers) that enable them to complete the recruitment processes
  • to conduct internal audits to demonstrate our compliance with relevant industry standards and regulations
  • 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

Automated decision takes place when an electronic system uses personal information provided by you, to make a decision without human intervention. We do not use automated decision-making on our website.

 

 

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 stored, processed and hosted inside the European Union (EU).

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 Work-Seeker 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.

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 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 of our General Privacy Policy.

 

 

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


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

HIRERS

We will process with or transfer your personal data to hirers in the education sector (e.g. primary schools, secondary schools, academies and other relevant types of educational establishments) in order to provide you with work-finding services. 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/registration information
  • Job preferences
  • School preferences and schools of interest (relating specifically to the hirer in question e.g. to feedback on 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)


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
  • 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 Candidate Profile/User Account by Signing In or by contacting us.
If you believe any other information we hold on you is inaccurate 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:

  • Email notifications from Crinkle Recruitment with general job notifications, advice, information, and tips
  • 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 General Email Alert preferences or by contacting us.

WITHDRAWING YOUR CONSENT AND DELETING YOUR INFORMATION

Withdrawing Consent: 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.

Deleting your information: In certain circumstances you may request us to delete all or some of personal information we hold for you.
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 still need to process or retain some or all of your personal information for legal or official reasons. We will inform you if this is the case. Where this is the case, we 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, we ask that your raise you concern with us in the first instance. Alternatively, you can 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 contact us 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, Crinkle Recruitment (Part of The Schools HR Co-operative Ltd), Unit 1 Britannia Court, The Green, West Drayton, Middlesex, UB7 7PN

 

 

9. Changes to this Work-Seeker Privacy Policy


We review this Work-Seeker Privacy Policy regularly and reserve the right to make changes at any time to reflect changes to business and legal requirements. If we revise this Work-Seeker Privacy Policy, we will contact you directly to notify you of our revisions and any actions that you may need to take as a result of changes to this privacy policy.