BACKGROUND:

Equiano Group Ltd (trading as Jonothan Bosworth) understands the importance of your privacy. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way, that is consistent with our obligations and your rights under the law.

WHO WE ARE:

Equiano Group Ltd (trading as Jonothan Bosworth)

Limited Company registered in England

Registered Address: 85 Great Portland Street, First Floor, London, W1W 7LT

Company Number: 8470034

VAT number: GB 164 3692 92

Data Protection Officer: Stuart Russell

ICO Data Protection Registration # ZA175169

Email address: hello@jonothanbosworth.co.uk (mark emails: FAO Data Protection Team)

Telephone number: 0845 299 6369

THE NOTICE:

This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also talks about your rights under the law relating to your personal data.

PERSONAL DATA:

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data in simple terms, is any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, banking details and other online identifiers.

YOUR RIGHTS:

Under the GDPR, you have the following rights, which we will always work to uphold.

This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more

The right to be informed about our collection and use of your personal data.

The right to access the personal data we hold about you.

The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.

The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.

The right to restrict (i.e. prevent) the processing of your personal details

The right to object to us using your personal data for a particular purpose or purposes.

The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business

Rights relating to automated decision-making and profiling.

Further information about your rights can also be obtained from the Information Commissioner’s’ Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

THE COLLECTION OF DATA:

We may collect some or all of the following personal data (this may vary according to your relationship with us):

Name

Address

Email address

Telephone number

Business name

Date of birth

Job title

Employment details (your CV, salary/rates, and experience/skills)

Education history

Information about your employment preferences

ID

References

National Insurance Number

Social Media profiles

Your personal data may be obtained from the following 3rd parties, however, we will never share your information with any external third party without your prior consent.

Job Boards

Social Media Accounts

LinkedIn

USE OF YOUR DATA:

Under the GDPR, we have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for one of the following purposes:

Supplying recruitment services to you

Communicating with you. This may include responding to emails or calls from you.

Supplying you with information by email and/or post that you have opted-in to

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and post with information, news, and updates on our services. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

RETENTION NOTICE:

We will delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for six years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data).

By “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate we will consider there to be meaningful contact with you if you submit your updated CV onto our website. Or if you communicate with us about potential roles, either by verbal or written communication or click through from any of our recruitment related communications.

Please note that we may need to continue to process your personal information in certain circumstances for specified periods up to seven years. This includes, but is not limited to, ensuring you have the right to work in the UK; allowing us to comply with HMRC reporting requirements regarding payroll information; or to establish, exercise or defend a legal claim.

TIME FRAMES ON PERSONAL DATA:

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. As we regularly work with candidates on a continuing basis and place them multiple times over several years, we may retain data on an ongoing basis.

STORAGE AND TRANSFER OF PERSONAL DATA:

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

Training employees on the importance of data protection

We use a cloud based CRM system whose data centres are ISO 27001 and PCI DSS compliant.

SHARING PERSONAL DATA:

We will share your personal data with prospective employers (for the purposes of providing recruitment services) only with your prior permission.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

ACCESS TO YOUR PERSONAL DATA:

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal address on this notice.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 5 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

LAWFUL BASIS & LEGITMATE INTEREST:

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

The lawful basis for the third party processing will include:

Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;

Satisfaction of their contractual obligations to us as our data processor;

for the purpose of a contract in place or in contemplation;

to fulfil their legal obligations.

Our legitimate interests in collecting and retaining your personal data is described below:

As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.

In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.

WEBSITE FUNCTIONALITY:

To use all features and functions available on the Website, you may be required to submit certain Data.

You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).

COOKIES:

This Website may place and access certain Cookies on your computer. Equiano Group Ltd (trading as Jonothan Bosworth) uses Cookies to improve your experience of using the Website and to improve our range of services. ‘Jonothan Bosworth’ has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling the provision of a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

This Website may place the following Cookies:

Type of Cookie Purpose Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. Analytical/performance cookies They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Functionality cookies These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). Targeting cookies These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

Please refer to our Cookie Declaration page for a list of all cookies used by our website

CHANGES TO THIS PRIVACY NOTICE:

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

This privacy policy applies between you, the User of this Website and Equiano Group Ltd (trading as Jonothan Bosworth), the owner and provider of this Website. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

CONTACT US:

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Stuart Russell

Email address: hello@jonothanbosworth.co.uk (mark emails: FAO Data Protection Team)

Telephone number: 0845 299 6369

Postal Address: Jonothan Bosworth, Business Hub, Council Offices, Codsall, South Staffordshire, WV8 1PX WV8 1PX