Candidate Privacy Notice
This notice was last updated on the 23rd April 2020.
The notice will be reviewed on an annual basis or when a change in legislation and/or practices dictates and any changes will be notified to you by posting an updated version on our websites and/or by contacting you via email.
We recommend that you regularly check for changes and review this notice when visiting our websites.
Commercial Services Group is committed to protecting your privacy. We take your privacy seriously and will only use the personal information that we collect from you or that you provide relating to the products and services you have requested from us or whereby you make an enquiry about our products or services.
If you have any concerns or questions relating to this notice, including how to update or access your personal information or to make a complaint, you will find our contact details in the Contact Us section below.
We are providing this privacy notice so you know who we are and what we do with any personal information we may collect.
This Privacy Notice explains
- Who the Commercial Services Group are
- What personal information we collect from you when you visit any of our websites, contact us or make an enquiry about any of our services or products
- How we collect, store and share personal information
- How we keep your personal information secure
- Your rights in relation to your personal information
- How you can make a Subject Access Request
- How you can make a complaint to the Information Commissioners Office (ICO)
By providing us with your information you consent to Commercial Services Group using your personal data as described in this notice.
1.1 WHO WE ARE
Commercial Services Group trades under the following recruitment brand names
Our legal entities that we trade under are
Commercial Services Kent Limited
Commercial Services Trading Limited
Commercial Services Group is a trading style of both Commercial Services Trading Ltd (Reg No. 5858178) and Commercial Services Kent Ltd (Reg No. 5858177). Both companies are wholly owned by Kent County Council and registered in England and Wales.
Our head office address is:
Commercial Services Group
1 Abbey Wood Road
If you have any questions, suggestions or complaints about the processing of your personal information please contact our Data Protection Officer (DPO) via email at firstname.lastname@example.org or in writing by using the address below;
Data Protection Officer
Commercial Services Group
1 Abbey Wood Road
2. HOW WE COLLECT PERSONAL INFORMATION
When you visit our websites or social media pages your personal information may be automatically collected by our web servers and/or cookies. This information could include your IP address, the date and the pages that you visit.
For more details about cookies and how we use them, please read our Cookie Notice
We collect this data in a variety of ways when you contact us directly via email, phone or face2face, through a job application via a jobs board, or when you create a job seekers account on our websites – www.connect2staff.co.uk or www.connect2kent.co.uk
We may also collect data about you from third parties, outside of the Commercial Services Group, including when you register as a candidate on a jobs board and make your profile searchable to recruiters. As a subscriber to some of these jobs boards, we will be able to view and download your personal details, but will only do so in relation to recruitment services.
We may approach previous employers in relation to employment references; we will inform you who we are approaching and when.
3. WHAT PERSONAL INFORMATION ARE WE COLLECTING
As part of the recruitment process, Commercial Services Group will collect and process personal data relating to job seeking candidates.
- your name, address and contact details, including email address and phone number
- Age, date of birth and gender, marital status, nationality and photo
- information likely to be included on your CV including details of your qualifications, skills, experience and employment/reference details
- details about your current employment, including salary and any additional benefits
- information pertaining to your rights to work in the UK, passport/driving licence or ID card
- information in relation to the Rehabilitation of Offenders Act (1974) and Criminal Records check
- bank details, national insurance number and statutory tax details
4. WHY WE ARE COLLECTING THIS INFORMATION
We collect your personal information in order to provide you with advice and an employment/job opportunities.
Commercial Services Group operates both temporary/contract and permanent recruitment services.
Temporary/contract recruitment – an assignment of temporary work placements with various clients across diverse industries within the private and public sector.
Under the provision of temporary/contract recruitment that Commercial Services Group offer, we collect personal information and retain data to enable us to match you to suitable temporary/contract positions. If you are successful and receive an offer for temporary/contract work, we will process and retain your bank details, national insurance number and statutory tax details in order to fulfil the legal requirement under the HM Revenue and Customs (HMRC) Real Time Information (RTI) regulations.
Permanent recruitment – the provision of promoting and sharing candidate’s personal details with clients, resulting in interviews and job offers/employment with those clients’ organisation.
Under the provision of permanent recruitment that Commercial Services Group offer, we collect & retain personal data to enable us to match you to suitable permanent positions. If you are successful and receive an offer for permanent work, we will retain your data to fulfil our statutory legal requirements (Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Conduct Regulations)).
5. OUR LEGAL BASES TO PROCESSING YOUR PERSONAL INFORMATION
There are a number of different legal bases that we may use in order to collect and/or process your personal information. These are listed below;
Commercial Services Group believe is reasonable to expect that if you are looking for a job and have applied via a jobs board, directly through our website or via any other means then Commercial Services Group have a legitimate interest to collect and otherwise process your data to offer or provide a recruitment service to you.
Where you have posted your CV on a jobs board and made your personal data searchable, Commercial Services Group may contact you in relation to a specific vacancy or speculatively for future employment. In this instance, we will contact you and gain your explicit consent to process and retain your personal data.
We will collect and process your personal information with your consent. Examples of this are when you tick a box to receive job or blog alerts on our website.
You may withdraw your consent at any time by contacting us at email@example.com or by using the unsubscribe links in our direct marketing emails.
When we have a contract with you we will collect and process your personal information in order to fulfil our contractual obligation. An example of this is where we have a contract for services with you. We will process your personal details to fulfil and manage the recruitment process.
We will use your personal information to comply with our legal obligations. This may mean that we need to provide your personal information to HMRC, DVLA and any other public authority. If requested we will provide the police with personal information to assist them with investigations.
6. RIGHTS OF ACCESS TO YOUR PERSONAL INFORMATION
Under current data protection law, you as an individual, have a number of rights in relation to the personal information we hold on you.
We may ask you to verify your identity or request more information about you in order for us to fulfil your request.
6.1 Your right to correcting and updating your personal information
If any of the information we hold about you, is inaccurate or out of date please contact us
6.2 Your right to erase your personal information
You may ask for your personal information to be erased from our systems by emailing us at the following email address firstname.lastname@example.org or by post to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.
We will comply with your request unless there is a lawful reason for us to continue to use and process your personal information.
6.3 Your right to restrict processing of your personal information
You have the right to restrict the processing of your personal information in the following circumstances
- Where you contest the accuracy of the personal information we hold on you
- Where you believe your personal information has been unlawfully processed
- Where you believe we no longer require your personal information for processing purposes or you require us to retain the information in order to establish, exercise or defend a legal claim
6.4 Your rights to the portability of your personal information
Your right to data portability allows you to obtain and re-use the personal information we hold on you for your own purposes. This will be provided to you in a structured, commonly used and machine-readable format (eg a CSV file). Machine-readable means that software can extract the data for other organisations to use. You can ask us to transfer your personal information directly to another service provider where technically feasible.
6.5 Your right to object to the processing of your personal information
You have a right to object about how we process your personal information on the following grounds;
- Processing based on legitimate interest
- Processing based on performing a task in the public interest including profiling
- Direct marketing
You can exercise your right to object by emailing or writing to us at the following email address email@example.com or by post to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.
You can also withdraw your consent and opt-out from direct marketing by using the unsubscribe link at the bottom of our marketing emails.
Suppression lists will be maintained to screen against direct marketing information being sent to people who have already exercised their right to object to direct marketing. These lists will be held for compliance purposes only, and this does not affect your rights to be erased.
6.6 Your rights relating to automated decision making (including profiling)
You have a right to understand and object to any automated decision making and/or profiling that is being carried out on your personal information (a decision made by automated means and without any human intervention). If you consent to receive Job and Blog alerts, we will use automated profiling based on your requirements, we do this because we want to provide you with information, products and services that are of interest and are most relevant to you.
You will need to make your request in writing to us and send your request to firstname.lastname@example.org
7. RIGHT TO LODGE A COMPLAINT
You have a right to make a complaint with the supervisory authority if you have any concerns about the collection or processing of your personal information. The supervisory authority is the Information Commissioners Office (ICO) whose contact details can be found on their website https://ico.org.uk/.
8. HOW WE PROTECT YOUR PERSONAL INFORMATION
We take the protection of your personal information seriously and will treat it with care and take appropriate steps to protect it.
What we do to protect your personal information.
- Our systems, services, software and equipment meet acceptable security standards (such as CyberEssentials)
- Our scanning security hardware and software are regularly checked to ensure they are functioning correctly
- Our computers are password protected and passwords are changed regularly
- Our systems are monitored for attacks and we carry out penetration tests to strengthen their security
- We store printed documents that contain personal information securely and ensure that they are only accessed by authorised personnel
- We securely dispose of any personal information that is no longer required
- We verify the identity of anyone requesting access to personal information prior to providing it
9. DATA STORED OR HANDLED OUTSIDE OF THE EUROPEAN UNION (EU)
Some of the personal information you provide to us may be transferred to countries outside the EU.
The companies we use that are based in the US have certified their compliance with the EU-US Privacy Shield https://www.privacyshield.gov/list
10. SPECIAL CATEGORY DATA
In some instances, Commercial Services Group may process special category data, such as information in relation to your ethnic origin, sexual preference or religion on behalf of our clients, in this instances Commercial Services Group we will be acting as a data processor.
The special categories of personal information we collect or process may include information about your;
- Ethnic origin
- Trade union membership
- Sexual orientation
We may also collect information about disabilities in order to make adjustments throughout the recruitment process, in order to carry out our obligations and exercise specific rights in relation to employment. In any event, we will notify and gain your consent to collect and process this information.
11. WE SHARE YOUR PERSONAL INFORMATION
Your data may be shared internally to enable us to manage the recruitment process. However, we will never share your data with our clients, without your permission; if we deem your application suitable for a role, we will inform you of the organisation and only with your explicit consent will we share your personal data with the hiring client.
The personal data of temporary applicants who receive and accept an assignment may be shared with previous employers to obtain references and employment background checks where required.
12. THE PROFILING WE DO
On some occasions, we may collect or process your personal information using automated decision-making systems (a decision made by automated means and without any human intervention). We do this because we want to provide you with information, products and services that are of interest and are most relevant to you.
13. OUR RETENTION POLICY
We do not retain your personal information for longer than is necessary. If your application is unsuccessful, and with your consent, Commercial Services Group may retain your personal data on our secure database, in order to assist you with any future job opportunities which you may be suitable for. You are free to withdraw your consent at any time.
The length of time we retain your personal information for will be determined by the type of information we collect and the purpose that it has been processed for and/or our obligations under other laws.
- personal information processed under contractual obligations will be retained for 12 months beyond the date of your temporary last assignment or last permanent placement
- the personal information of temporary workers will be retained for 7 years to fulfil our HMRC obligations
- jobseeker personal information (e.g. CV) will only be retained for 24 months unless you have exercised your right for your personal information to be erased or you have objected to your information being processed
- we will hold your personal information for marketing purposes unless you have opted out or unsubscribed from receiving marketing information
If you have any concerns about our retention period please contact the email@example.com
14. LINKS TO OTHER WEBSITES
- Our privacy notice only applies to Commercial Services Group website and its divisions (for a full list of divisions see Who We Are)
Our websites may contain links to other organisations’ websites, which we do not control. These websites are owned and operated by a third party and they are responsible for processing personal data in accordance with their own privacy policies