Approach Personnel Ltd (‘The Company’)
Date of Publication
25th January 2023
Approach Personnel Ltd is acting as a recruitment business which provides work-finding services to its clients and work seekers. The Company must process personal data (which may include sensitive personal data) so that it can provide these services. In doing so, the Company acts as a Data Controller.
Examples of data we may collect from you:
- Date of Birth
- Contact details, including telephone number, email address and postal address
- Experience, training, qualifications/certification
- National Insurance Number
- Other relevant personal data (including bank account details, driving license information/ status) etc
Sensitive personal data
- Disability/health condition relevant to the role
- Any unspent criminal convictions
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 them from another source such as job boards. 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 the terms of the following statement.
1. Collection and use of personal data
a. Purpose of processing and legal basis
The Company will collect your personal data and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, adding to/ updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.
In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us.
We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to offer these services to you are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have
- To fulfil a contractual obligation that we have with you
b. Legitimate interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the company has relied on a legitimate interest to process your personal data our legitimate interest is/are as follows:
- Finding you suitable temporary work assignments;
- Sending your details to third party payroll service providers or umbrella companies in order to get you registered for work and weekly payments, this includes your provided bank details;
- Finding you a suitable permanent job;
- Managing our database and keeping your work-seeker record up to date;
- Contacting you to seek your consent where we need it;
- Providing work finding services to you, including sending your information to our clients where you have demonstrated an interest in doing a particular type of work;
- Contacting you with the information about job opportunities that we feel may be of interest to you;
- Passing on work references to future employers when requested
c. Recipient/s of data
The Company may process your personal data and/or sensitive personal data with the following recipients:
- The Company’s clients that we introduce or supply individuals to;
- Your former or prospective employers in order to obtain or provide references;
- The Recruitment and Employment Confederation or any other trade body who may have access to your data;
- Any other third parties who carry out audits to ensure that we run our business correctly;
- Third party payroll service providers or umbrella companies who will manage your weekly payment;
- Other recruitment agencies in the supply chain (e.g. master/neutral vendors and second tier suppliers);
- Our insurers;
- Our legal advisers;
- Social Networks;
- Our IT and CRM providers
- Public information sources and third-party organisations that we may use to carry out suitability checks on work-seekers e.g. Companies House, The Disclosure and Barring Service (DBS), DVLA and credit reference agencies;
- Government. law enforcement agencies and other regulators e.g. the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs), Gangmasters and Labour Abuse Authority (GLAA)
2. Data retention
The Company will retain your personal data only for as long as necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.
We must also keep your payroll records, holiday pay, sick pay and pension’s auto-enrolment records for as long as legally required by HMRC and associated national minimum wage, social security and tax legislation purposes.
Where the Company has obtained your consent to process your personal data, we will retain this for a minimum period of 5 years. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data.
3. Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company processes on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling;
- The right 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 our head office administration team (contact details below), or using the unsubscribe option on email correspondence.
There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is is necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details below and we will take reasonable steps to check its accuracy and correct it where necessary. You can also contact us if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
4. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact our office administration team. The contact details are below;
Address:Unit 8 Chase Park, Daleside Road, Nottingham, NG2 4GT
You also have the right to raise concerns with the 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.