Privacy Policy

1. Collection and use of personal data

Purpose of processing and legal basis

We collect and process personal data for the purposes of providing work-finding services. This may include:

• Contacting you about job opportunities;
• Assessing your suitability for opportunities;
• Updating and maintaining our databases;
• Putting you forward for job opportunities;
• Arranging payments where applicable; and
• Developing and managing our services and our relationships with you and our clients.

In some circumstances, we may also be required to use your data for investigating, reporting or detecting crime, complying with applicable laws, or demonstrating compliance with relevant industry standards.

Our legal bases for processing personal data may include:

• Your consent;
• Our legitimate interests;
• Compliance with a legal obligation; and
• Fulfilling a contractual obligation we have with you.

Legitimate interests

A legitimate interest is a legitimate reason for processing your data where that processing is reasonable and does not override your rights and interests. Our legitimate interests include:

• Managing our database and keeping work-seeker records up to date;
• Providing work-finding services to candidates and clients;
• Contacting you to seek consent where this is required; and
• Providing information about similar services you have recently used from us.

Statutory and contractual requirements

We have certain legal and contractual requirements to collect personal data. These can include obligations under the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation and, in some circumstances, safeguarding requirements.

Our clients may also require certain personal data, and we may need your information in order to enter into a contract with you. If you do not provide information that we are required to collect, we may be unable to continue providing work-finding services to you.

Recipients of your data

Where appropriate, your personal and/or sensitive personal data may be shared with:

• Clients to whom we may introduce or supply you;
• Former employers from whom we seek references;
• Payroll service providers or other payment intermediaries; and
• Other recruitment agencies within a supply chain.

2. Information we may collect

Categories of personal data

Depending on our relationship with you, we may collect:

• Your name, title, address, telephone number and email address;
• Your gender, date of birth, nationality and place of residence;
• Your professional skills and experience;
• Your qualifications, training and certifications;
• Evidence of your right to work in the United Kingdom;
• Proof of identity and address;
• Details of your current or most recent employment;
• Your salary, benefits and notice period;
• Your reasons for seeking alternative employment;
• Information contained within your CV or application documents;
• Information you provide during your dealings with us;
• Details of clients to whom you have been introduced;
• Interview details and client feedback; and
• Details of positions you take up with a client.

Freelance services

If you provide services on a freelance basis, we may also collect:

• Details of any limited company through which you contract;
• Information about the days and times you have worked;
• Your bank details, tax code and National Insurance number; and
• Information and feedback relating to services you have carried out.

Special category and sensitive information

Where relevant and where we have a lawful basis to do so, we may collect, store and use more sensitive information, including:

• Information about race or ethnicity;
• Health information, including disabilities or medical conditions; and
• Information about criminal convictions and offences.

Sources of personal data

We may receive information directly from you where you have:

• Applied for a client vacancy through us;
• Uploaded or provided your CV;
• Asked us to provide work-finding services;
• Engaged with us through networking activities or events; or
• Discussed alternative employment with us.

We may also obtain information from professional networking sites such as LinkedIn, social networking sites, recruitment and job boards, referees, employer and industry websites, business information directories, industry databases and, where appropriate, third-party background checking services such as the Disclosure and Barring Service.

3. Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected. Different laws may require information to be retained for different periods.

For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003 requires certain work-seeker records to be retained for at least one year from their creation or from the date on which we last provided work-finding services.

Payroll, holiday pay, sick pay and pension auto-enrolment records may also need to be retained for periods required by HMRC and applicable national minimum wage, social security and tax legislation.

Our retention policy

When determining an appropriate retention period, we consider the amount, nature and sensitivity of the information, the potential risk arising from unauthorised use or disclosure, the purposes for which it is processed and applicable legal requirements.

Our standard data retention period is three years from the last date on which we are in actual contact with you, such as when we speak with you or exchange correspondence.

After this period we will usually delete personal data from our records unless we have a lawful reason to retain it. We will not use your personal data for recruitment purposes where we have not been in actual contact with you for three years or more.

Where information must be retained for auditing or compliance purposes, contractual obligations to third parties, or potential or actual legal proceedings, we will retain it only for as long as reasonably necessary. This will typically be up to seven years from the relevant activity.

In some circumstances, information may be fully anonymised so that it can no longer be associated with an individual. Such information may then be retained indefinitely because it is no longer personal data.

4. Your rights

Depending on the circumstances, your data protection rights include:

• The right to be informed about the personal data we process;
• The right of access to your personal data;
• The right to rectification of inaccurate or incomplete data;
• The right to erasure in certain circumstances;
• The right to restrict processing;
• The right to data portability in certain circumstances;
• The right to object to processing based on legitimate or public interests;
• Rights relating to automated decision-making and profiling; and
• The right to withdraw consent at any time where consent is the basis for processing.

Where you have consented to us processing your personal data, you may withdraw that consent at any time by contacting Richard Livermore, Director. Withdrawal of consent does not affect processing already carried out or processing performed under another lawful basis.

There may be circumstances in which we must continue processing certain information for legal or official reasons. Where applicable, we will restrict that processing to what is necessary for those purposes.

If you believe information we hold about you is inaccurate or incomplete, or you wish to exercise any of your data protection rights, please contact us using the details below.

5. Log files

We may use IP addresses and server log information to analyse trends, administer and secure the website, understand use of the site and gather aggregate information.

6. Links to external websites

Our website may contain links to external websites. Melior Associates is not responsible for the privacy practices of those sites. When leaving our website, we recommend reviewing the privacy information provided by any external website that collects personal information.

This privacy policy applies to information collected by Melior Associates.

7. Sale of the business

If the business is sold or integrated with another business, personal information may be disclosed to our advisers, prospective purchasers and their advisers and may subsequently be transferred to the new owners of the business.

8. Data security

We take reasonable precautions to protect personal information, including appropriate technical and organisational security measures, restricted access and password controls.

Access to personal information is limited to people who require it to perform their role.

Although we take reasonable steps to safeguard personal information, email and internet communications cannot be guaranteed to be completely secure.

If you have questions about data security, please contact richard.livermore@meliorasc.com .

9. Changes to this privacy policy

We may update this privacy policy from time to time. Changes will be published on this page and, where appropriate, material changes may also be communicated directly.

10. Complaints or queries

If you have a question about this privacy policy, our handling of your information, or wish to make a complaint, please contact:

You also have the right to raise concerns with the Information Commissioner's Office (ICO) on 0303 123 1113, or another relevant supervisory authority where applicable.