This Data Protection Policy outlines the way in which we manage the data we hold for our Candidates (“you”), for and about whom it is necessary to hold and process data in the provision of our recruitment and associated services.
For the purpose of applicable data protection laws (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the companies to which this document relates is ion-tec Limited (together, the, “we” or “us”).
This is a controlled document that may be updated from time to time. Please visit this web page to ensure you are reading the latest version: www.ion-tec.com
Ion-tec Limited operates as a data controller of Candidate personal data under the GDPR, which means we are responsible for deciding how we hold and use your personal information. This Data Protection Policy is intended for individuals applying for work with us as a Candidate. It makes you aware of how and why your personal data will be used and how long it will usually be retained for. It provides you with certain information that must be provided under the GDPR, including information about your rights in respect of your personal data.
“Candidates” includes applicants for all roles advertised or promoted by ion-tec Limited (including permanent, contract and interim positions) with any ion-tec Limited clients; as well as people who have supplied a speculative CV to ion-tec Limited not in relation to a specific job. Individual contractors, interim consultants and employees of suppliers or other third-parties put forward for roles with ion-tec Limited clients as part of a managed service provision or otherwise, will also be treated as Candidates for the purposes of this Data Protection Policy.
Ion-tec Limited is committed to presenting Candidates with attractive and relevant opportunities with organisations that we consider will be relevant to your career aspirations. In order to achieve this, it is necessary for us to process information about you from the various sources we have available to us. We will only ask for and use information about you that is necessary for us to provide you and our clients with the very best levels of service. There may also be a need, in providing recruitment services, for us to provide information to carefully selected suppliers and other 3rd parties in order to meet our contractual and legal obligations. Our commitment to you is that we will only process your personal data to the extent required in order to meet these objectives.
We will comply with data protection laws and principles in respect of your personal data, which means that your personal data will be:
Depending on the relevant circumstances and applicable legal and contractual requirements, we may collect, store and use some or all of the information listed below to enable us to provide you with candidate services.
Types of general data held:
Some of the personal data we collect, store and use falls into the following "special categories" of more sensitive personal information:
We will use your particularly sensitive personal information in the following ways:
We envisage that we may need to process information about criminal convictions where we have been asked to do so by our clients, or where a particular role requires a criminal record check. Where this is the case, we will collect information about your criminal conviction/s history if we or our client would like to offer you the position. We may be required by our client to carry out a criminal record check in order to confirm that there is nothing in your criminal convictions history which makes you unsuitable for a particular role.
We have in place appropriate safeguards which we are required by law to maintain when processing such data.
We collect Candidate personal data in 3 main ways:
You can provide your personal data directly to us in the following ways:
The following methods outline the ways in which we can receive personal data about you as a Candidate:
We will use the personal information we collect about you for the following broad purposes (“lawful purposes” under the GDPR):
More specifically we use your personal data for the following purposes:
Legitimate Interests
It is in our legitimate interests to decide whether to contact you about particular roles and/or forward your application to appropriate clients and assist in taking your application forward. This is because it is beneficial to our business to recommend suitable and appropriately qualified Candidates to our clients and to help match our Candidates to appropriate roles that are relevant to the Candidate’s wishes.
We may also provide a prospective employer or client with information you have provided to us (for example, the results of psychometric or skills tests) or to confirm your references, qualifications and criminal record, where this is appropriate and in accordance with EU laws.
We share this type of information in order to further our legitimate interests as a profit-making business providing recruitment services to our clients.
We may also contact you more generally to discuss and align your employment needs and career development with opportunities we can present you with and relevant information and articles we can provide to you. This is because it is in our legitimate interests to ensure that our Candidates are offered relevant, appropriate opportunities which correspond with their own career aspirations.
We may also from time to time provide the opportunity for you to contribute to interactive services such as surveys or social media content. This allows us to differentiate ourselves as a recruitment provider and compete within our market and is therefore within our legitimate interests to process your data in this way. We will always check beforehand that you are happy for us to use your data in this way.
We may send you direct marketing material from time to time. The use of your personal data for this purpose will be proportionate, have a minimal privacy impact, and will be highly relevant to the service provided. You will always be given the opportunity to unsubscribe from such material.
Contractual Obligations
We may also need to process your personal information for the purposes of entering into or performing a contract of employment or contract for services with you. This will include carrying out our internal administrative processes such as payroll processes if we engage you as a contractor/consultant, or in order to raise invoices.
Legal Obligations
We are required as part of our recruitment process to seek, confirm and hold certain Right to Work documents about you such as a passport or ID card copy, proof of address or UK driving licence in order to process you as a Candidate for a vacancy that could result in your employment within the EU.
We must also comply with our wider legal obligations. We may therefore share your data in connection with crime detection, tax collection or litigation activity, whether actual or anticipated.
If You Cannot Provide Any Relevant Data
If you fail to provide information when requested, which is necessary for us to consider or progress your application (such as evidence of qualifications or work history), we may not be able to progress your application successfully or recommend you to our full range of clients.
For example, if one of our clients requires that employees are subject to a credit check or references for a particular role and you fail to provide us with relevant details, we may not be able to take your application further.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third-parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Where appropriate and in accordance with data protection laws, we may share your personal data with the following third-parties:
If you would like further information about the specific identities of the third-parties listed above, please contact us at the following email address info@ion-tec.com To ensure that your personal information is subject to an adequate level of protection, Whitewing Recruitment & Training Services Limited has in place appropriate procedures with the third-parties we share your personal data with to ensure that your personal information is treated securely by those third-parties in a way that is consistent with and which respects the law on data protection. Our third-party suppliers do not use your personal data for their own purposes, and we only permit them to process your personal data in accordance with our instructions.
For those Candidates who are placed in a contract position, and therefore become a consultant engaged via a third-party company or other entity, the relationship changes to a contractual one. As a result we will retain your data for six years (or longer, if required by statute or other regulation). Your data and that relating to the company or other third-party entity through which you supply services, will be deleted within six months of the sixth anniversary of the termination or expiry of our contractual relationship with the entity through which you supply your services (or longer as required by statute or other regulation).
If, after six years following the termination or expiry of our contractual relationship, we continue to have meaningful contact with you as a Candidate (for example if you continue to wish to be considered for contract or permanent recruitment opportunities), we will continue to retain the data relating to you and the company or other third-party entity through which you supply services while we maintain meaningful communication with you. We will delete your data within 6 months following the second anniversary of our last meaningful contact with you.
"Meaningful contact" with contractors/consultants will include any of the following:
Meaningful contact with you means meaningful contact as described above, either with you directly or, where applicable, with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will delete your data within 6 months of the 1st anniversary of our last meaningful contact with the company or third-party entity through which you supply services; or, if later, within six months following the second anniversary of our last meaningful contact directly with you.
Under the GDPR, as an EU citizen or individual within the EU you retain various rights in respect of your data under certain circumstances, even after you have provided it to us. To get in touch about these rights, please contact us at info@ion-tec.com We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
You have the right to object to us processing your personal data in certain circumstances.
This right is most likely to be enforceable by you where we are processing data for one of the following reasons:
The GDPR states that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third-party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
The activities identified in Section 4 above (HOW AND WHY WE WILL USE YOUR DATA) are undertaken for our legitimate interests to help us to provide you with a professional, personalised, and effective service. You do, however, have the right to object to us processing your personal data on this basis. If your objection relates to us processing your personal data on the basis of legitimate interests, we must act on your objection by ceasing the activity in question unless:
If your objection relates to direct marketing, we will act on your objection by ceasing this activity.
Where you have provided your consent for us to process your personal data for certain activities (for example, to contact you about potential roles that may be of interest to you, or for marketing activities), you may withdraw this consent at any time and we will cease to carry out the specific activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data. If this is the case, we will inform you of the reason(s) for our continued processing.
If you have posted your CV or other related personal information publicly on a job board or professional networking site, we understand that you have given your consent via your application on the job board or networking site for Whitewing Recruitment & Training Services Limited to collect and otherwise use your personal data in order to contact you to offer or provide recruitment services to you. We will review your publicly posted information to assess your skills, qualifications and other relevant information provided in relation to the vacancies we are sourcing Candidates for. If we consider you may be suitable for a potential role we will share your information with prospective employers, but we will never pass your details to a prospective employer without your explicit consent.
You may ask us to confirm what information we hold about you at any time, and to provide a copy of the personal data we hold. In order to process your request, we may need to verify your identity and ask for additional information regarding your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative fee where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will inform you of our reasons for doing so.
You have the right to request that we erase your personal data in certain circumstances.
Normally, a valid request must meet one of the following criteria:
We are legally entitled to refuse to comply with your request where our continued processing is necessary for one of the following reasons:
When complying with a valid request for the erasure of data we will take all reasonablypracticable steps to delete the relevant data.
You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either:
You are entitled to request that we restrict the processing of your personal data in the following circumstances:
If we have shared your personal data with third-parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort on our part. We will, notify you before lifting any restriction on processing your personal data.
You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third-parties, we will notify them about the rectification and ask them to correct their records unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third-parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
If you wish, you have the right to ask us to transfer your personal data between data controllers. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another provider. Please note that this right of data portability does not apply to all data we hold about you, but applies to:
You also have the right to lodge a complaint with your local supervisory authority, which in the UK is the Information Commissioner’s Office.
If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
You may unsubscribe from direct marketing communications and SMS messaging at any time by clicking the “Unsubscribe” link in each message.
It is important that the personal information we hold about you is accurate and current.
Please keep us informed if your personal information changes during the period for which we hold your data.
In order to ensure you are presented with the best service possible, your data may be transferred:
We will only transfer data outside of the EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection laws and the means of transfer provides adequate safeguards in relation to your data, for example:
Please contact us on info@ion-tec if you would like further information about the specific mechanism used by us when transferring your personal data outside of the EEA.
This document applies to:
Ion-Tec Limited Registered in the UK