Privacy Policy - Keeler Recruitment

Keeler Recruitment Limited of Riverside Business Centre, 61-63 Riverside Road, Norwich, Norfolk, NR1 1SZ
(“we”) are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data about you will be processed by us. Please read
the following carefully to understand our views and practices regarding your personal data and how we will
treat it.

For the purpose of the General Data Protection Regulations 2016, the Data Protection Act 2018 and any
and all other applicable laws and regulations relating to the processing of personal data and privacy (“the
Data Protection Legislation”), we act as the data controller.

1. Information we collect
1.1 We may collect and process the following data about you:

1.1.1 information about you that you give us by filling in details on our website located at the domain name www.keelerrecruitment.co.uk (“our Website”) or by corresponding with us by phone, e-mail, Linkedin, social media (including, but not limited to, Facebook, Twitter, Instagram) or otherwise. The information you give us may include your name, address, e-mail address and phone number, gender, date of birth, financial and credit card information and other relevant information (including special category personal data) from your curriculum vitae (CV);

1.1.2 records of interviews that we have arranged for you and your specific job interest requirements including but not limited to salary expectations, location and job role;

1.1.3 if you contact us, we may keep a record of that correspondence;

1.1.4 if you complete surveys that we use for research purposes (although for the avoidance of doubt you do not have to respond to such surveys), the information which you provide in response to that survey;

1.1.5 the substantive outcome of any testing carried out with you by third parties on behalf of prospective employers;

1.1.6 technical information regarding your visits to our Website including, but not limited to, the Internet protocol (IP) address used to connect your computer to the Internet, geographical location, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

1.1.7 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), job vacancies you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.

2. IP addresses and Cookies

2.1 We may collect information about your computer, including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

2.2 Our Website may use cookies to distinguish you from other users of our Website. Cookies contain information that is transferred to your computer’s hard drive. This helps us to provide you with a more personalised service when you browse our Website and also allows us to improve our Website.

2.3 You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Website.

3. How we use your personal data

3.1 We may use the information which we collect and hold about you in the following ways:

3.1.1 to carry out our obligations arising from any contracts entered into between you and us as is necessary for the performance of our contract with you;

3.1.2 to provide you with the information and services that you request from us prior to entering into a contract with us;

3.1.3 to provide you with information which you request from us as is in our legitimate interest to do so;

3.1.4 to answer your enquiries in accordance with our legitimate interests;

3.1.5 to maintain our business relationship with you, where you are a user of our Website as a client or potential candidate in accordance with our legitimate interests;

3.1.6 in respect of candidates who have applied to work for Keeler Recruitment Limited, to allow us to process and evaluate your application or CV in respect of any job vacancy with us that you have applied for as a step prior to entering into any contract with you;

3.1.7 to process information about you which may include references, qualifications, verification of details you have provided from third party sources, results of psychometric evaluations or skills tests as it is in our legitimate interests to do so;

3.1.8 to notify you about changes to our service as is in our legitimate interests to do so;

3.1.9 to provide you with information about other services we offer that are similar to those that you have already been provided with where it is in our legitimate interests to do so. You may unsubscribe at any time from receiving further communications from us for these purposes;

3.1.10 to provide you with information about services we feel may interest you (including but not limited to employment situations), any news or industry updates, upcoming events or other information, where you have consented to be contacted for such purposes. You may unsubscribe at any time from receiving further communications from us for these purposes;

3.1.11 to ensure that content from our Website is presented in the most effective manner for you and for your computer as is in our legitimate interest;

3.1.12 to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes so as to allow us to provide you with the best possible service and experience as is in our legitimate interest to do so;

3.1.13 as part of our efforts to keep our Website safe and secure as is in our legitimate interest; and

For the purposes of the above, our ‘legitimate interests’ include the proper administration, monitoring and improvement of our business and the Website, the promotion of our business including direct marketing and the maintenance of the goodwill and reputation of Keeler Recruitment Limited which includes the provision of excellent customer service and care.

Please note where we require personal information from you in order to process or evaluate your CV or application your failure to provide the requested personal information may mean that we are unable to proceed with the processing of your application or CV, we will inform you where this is the case.

4. Providing your personal data to others

4.1 We may share your personal information with:

4.1.1 Our clients as prospective or intended employers (or third parties assisting them in the recruitment process) as it is in our legitimate interest to do so.

4.1.2 Selected third parties including those who are providing services such as reference, qualification and criminal reference checking services, verification of the details you have provided from third party sources, psychometric evaluations or skills tests as it is in our legitimate interest to do so.

4.1.3 Selected third parties who perform functions on our behalf and who also provide services to us, such as professional advisors and IT consultants carrying out testing and development work on our business technology systems and providing IT support and server back up as it is in our legitimate interest to do so.

4.1.4 We will disclose your personal information to third parties:

4.1.4.1 In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets as part of the sale or purchase process in order to allow such transaction to complete as is in our legitimate interest to do so;

4.1.4.2 If Keeler Recruitment Limited or substantially all of its assets are acquired by a third party or its business merges with another business or company, we may share personal data with the new owners of the business or company or their professional advisers as is in our legitimate interests to do so; and

4.1.4.3 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Keeler Recruitment Limited, our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction as it is in our legitimate interests to do so.

5. Where we store your personal data and international transfers of your data

5.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) which has not been confirmed as having adequate levels of protection for personal data and which does not benefit from an adequacy decision issued by the European Commission. It may also be processed by staff operating outside the EEA who work for us. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy including ensuring that the transfer is made subject to appropriate safeguards including the use of standard data protection clauses approved by the

European Commission.

5.2 All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website or candidate database (namely the part relevant to you), you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

5.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

6. Retaining and deleting personal data

6.1 We shall ensure that any personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain and delete your personal data as set out at clause 1 for a period of five years from the last query, instruction, CV submission and/or application we receive from you, at the end of which period it will be deleted from our systems. This is because we consider that it is in our legitimate business interest to retain the data for this period of time, after which period it is no longer relevant.

6.2 Notwithstanding the above, we may retain your personal data where such retention is necessary for compliance with our legal obligations.

6.3 Subject to clause 7.2 below, we will retain limited personal data for an indefinite period of time pertaining to candidates as follows:

6.3.1 in the event that we no longer wish to work with a candidate, we shall retain their name, email address, telephone number, most recent place of work and the reason for not working with the individual; and

6.3.2 where we have placed a candidate in employment with one of our clients, we will retain a candidate’s name and a record as to which client we placed them with.

7. Your rights

7.1 You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at Keeler Recruitment Limited, Riverside Business Centre, 61-63 Riverside Road, Norwich, Norfolk, NR1 1SZ or by clicking the unsubscribe link on any marketing communication we send to you by email.

7.2 You can exercise the right to request any amendments or rectifications to your personal data by contacting us at the above address and can use this address to notify us if you would like us to delete or erase your data or, in certain circumstances, if you would like us to restrict the manner in which we process your data. Please note in certain circumstances we may not be able to delete or erase your personal data such as where this is still required for the purpose for which it was provided or where we have overriding legitimate interests in retaining your data.

7.3 Where you have given us your consent to the specific processing of your personal data please note you have the right to withdraw that consent at any time. Should you wish to withdraw your consent please contact us at the address above.

7.4 Our Website may, from time to time, contain links to and from external websites as a service to our visitors. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. The provision of a link on our Website to an external website should not be taken as an endorsement by us of that external website, its owners or their products / services.

8. Access to information

8.1 The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation by contacting us at Keeler Recruitment Limited, Riverside Business Centre, 61-63 Riverside Road, Norwich, Norfolk, NR1 1SZ.

9. Changes to our privacy policy

9.1 Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

10. Complaints

10.1 If you are unhappy with the way in which we have collected or processed your personal data or have any other complaint in relation to our handling of your personal data, you can make a complaint to the Information Commissioner. Further information can be found on the Information

Commissioner’s website at www.ico.org.uk or via their helpline on 0303 123 1113.

11. Contact

11.1 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Keeler Recruitment Limited, Riverside Business Centre, 61-63 Riverside Road, Norwich, Norfolk, NR1 1SZ or by contacting us by email at [email protected]

2.2 Our Website may use cookies to distinguish you from other users of our Website. Cookies contain
information that is transferred to your computer’s hard drive. This helps us to provide you with
a more personalised service when you browse our Website and also allows us to improve our
Website.

2.3 You may refuse to accept cookies by activating the setting on your browser which allows you to
refuse the setting of cookies. However, if you select this setting you may be unable to access
certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse
cookies, our system will issue cookies when you log on to our Website.

3. How we use your personal data

3.1 We may use the information which we collect and hold about you in the following ways:

3.1.1 to carry out our obligations arising from any contracts entered into between you and us as is
necessary for the performance of our contract with you;

3.1.2 to provide you with the information and services that you request from us prior to entering into a contract with us;

3.1.3 to provide you with information which you request from us as is in our legitimate interest to do so;

3.1.4 to answer your enquiries in accordance with our legitimate interests;

3.1.5 to maintain our business relationship with you, where you are a user of our Website as a client or
potential candidate in accordance with our legitimate interests;

3.1.6 in respect of candidates who have applied to work for Keeler Recruitment Limited, to allow us to
process and evaluate your application or CV in respect of any job vacancy with us that you have
applied for as a step prior to entering into any contract with you;

3.1.7 to process information about you which may include references, qualifications, verification of
details you have provided from third party sources, results of psychometric evaluations or skills
tests as it is in our legitimate interests to do so;

3.1.8 to notify you about changes to our service as is in our legitimate interests to do so;

3.1.11 to ensure that content from our Website is presented in the most effective manner for you and for your computer as is in our legitimate interest;

3.1.13 as part of our efforts to keep our Website safe and secure as is in our legitimate interest; and

3.1.14 in certain circumstances, to process special category personal data, (which includes data relating to criminal records, your racial or ethnic origin, your political opinions, your religious or philosophical beliefs or trade union membership and data concerning your health and any disabilities, your sex life or sexual orientation) and to send your CV and personal data to our clients in order for you to apply for a job vacancy where you have specifically requested we do so and where we have your informed consent to do so.
For the purposes of the above, our ‘legitimate interests’ include the proper administration, monitoring and improvement of our business and the Website, the promotion of our business including direct marketing and the maintenance of the goodwill and reputation of Keeler Recruitment Limited which includes the provision of excellent customer service and care.

4. Providing your personal data to other

4.1 We may share your personal information with:

4.1.1 Our clients as prospective or intended employers (or third parties assisting them in the recruitment process) as it is in our legitimate interest to do so.

4.1.4 We will disclose your personal information to third parties:

5. Where we store your personal data and international transfers of your data

European Commission.

6. Retaining and deleting personal data

6.2 Notwithstanding the above, we may retain your personal data where such retention is necessary for compliance with our legal obligations.

6.3 Subject to clause 7.2 below, we will retain limited personal data for an indefinite period of time pertaining to candidates as follows:

6.3.2 where we have placed a candidate in employment with one of our clients, we will retain a candidate’s name and a record as to which client we placed them with.

7. Your rights

8. Access to information

9. Changes to our privacy policy

10. Complaints

11. Contact