Personal Information is any personally identifiable information, such as your email address, name, home or work address, telephone number, bank details or tax codes, which can directly or indirectly identify you. We refer to it as “Personal Information” here.
When you interact with us in the different ways described below, we may ask you for the following information:
We may also collect sensitive Personal Information about you (including details of your physical or mental health, racial or ethnic origin, criminal allegations or offences, trade union membership and/or other sensitive Personal Information that you may choose to provide to us voluntarily from time to time.
We collect and use your Personal Information because it is necessary to obtain certain details including Personal Information from you in the work-searching process and it is in our legitimate interests in the course of operating our business, including:
However we will only collect, use and handle your Personal Information when:
We undertake the following processing of your Personal Information on the legal basis that it is necessary to perform the contract with you and to provide the services we have agreed to provide to you. Where we have not entered into a contract with you, we may also carry out this processing because in that pre-contractual stage where we consider it is necessary in our legitimate business interests in order to deal with requests, enquiries or comments you have made to us.
Submission of details to clients – if you register to apply for a particular role, request to be put forward for a role or if you have asked us to put you forward for suitable roles, we will share some of your personal details including your name, work history and qualifications with our clients offering potential roles which might be suitable for you.
On-boarding for a work-assignment – If you are offered and accept a work assignment through us, we will need further Personal Information from you such as NI number, bank details, emergency contact details and some medical information in order to fulfil our statutory and contractual obligations to both you and our client.
Reporting to clients and managing timesheets, payroll and work performance – We sometimes have to prepare reports for clients relating to the services provided by us for example reports on financial or administrative matters or compliance with legal requirements. Such reports may contain your Personal Information such as your name, hours worked and pay rate. In addition we may need to manage submission of timesheets, payroll services and other Human Resourcing services such as managing your statutory rights and work appraisals for our clients, all of which would require use of your Personal Information.
Other lawfully permitted processing – We may also use any Personal Information that you provide to us for example to other companies within the Change Exchange Group or to employers or any other company who you ask us to approach on your behalf for work-searching purposes If you choose not to provide Personal Information requested by us, we may not be able to provide you with the services and/or information you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information, including placing you in a work-assignment. We will where possible anonymise or aggregate such data for reporting purposes.
Pre-Assignment vetting – we collect your Personal Information which you provide to us when applying for a role or registering for our job-finding services to comply with our (and clients’) legal obligations regarding your right to work and any necessary qualifications for roles,. We may also process your Personal Information for this purpose where we consider it necessary for performance of the contract with you, or otherwise with your consent
We undertake the following processing of your Personal Information with your consent.
Marketing – where legally permitted to do so where you have provided us with your contact details and have agreed to be contacted for marketing purposes, we may contact you by telephone or by post for marketing purposes relating to our services, our website, and/or to research opinion on proposed business developments. Your agreement to the use of your Personal Information for these purposes is optional (see Marketing Opt-out below) and if you fail to provide your agreement, your use of our work-finding services will not be affected.
Marketing Opt-Out – you are entitled to opt out of marketing at any time and free of charge here or by using the “unsubscribe” option included in any marketing e-mail or other marketing material received from us.
Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your Personal Information is adequately protected. The third parties may include our clients, suppliers of IT services, pay-rolling services or vetting services.
Where we employ third party companies or individuals to process Personal Information provided by us on our behalf for business functions, including (without limitation) IT support, hosting our data on cloud platforms, legal, accounting, audit, consulting and other professional service providers, and providers of other services related to our business.
Portions of our services may be provided by organisations with which we have a contractual relationship, including subcontractors, and, accordingly, your Personal Information may be disclosed to them. We only provide these organisations with the information that they need to be able to perform their services.
We will have in place an agreement with our service providers which will restrict how they are able to process your Personal Information.
We may also provide your information to other third parties such as regulators and law enforcement agencies, where we are required by law to do so, where necessary for the purposes of preventing and detecting fraud, other criminal offences and/or to ensure network and information security.
We employ appropriate security measures to help protect your Personal Information and guard against access by unauthorised persons. Information storage is on secure computers in a secure environment, or in secure, locked storage in the case of hard copy information. The information is encrypted wherever possible and we undergo periodic reviews of our security policies and procedures to ensure that our systems is secure and protected. However the transmission of information via the Internet is not completely secure so we cannot guarantee the security of your information when it is transmitted to our website or from third party websites such as job boards.
You may withdraw from marketing at any time. It is important to us that you are in control of your own information. As a result, we offer the following controls:
You may request access to or copies of the Personal Information that we hold about you. If you would like to exercise this right, please contact us at GDPR@change-exchange.com or the address below. If your request is made before 25 May 2018, we may charge you a fee of £10 for such access, and in some circumstances more for the provision of copies;
If you believe that any information we have about you is incorrect or incomplete, please contact us firstname.lastname@example.org as soon as possible. We will take steps to seek to correct or update any information if we are satisfied that the information we hold is inaccurate. You may request that we restrict our processing;
You may request that your Personal Information be deleted, where it is no longer necessary for the purposes for which it is being processed and provided there is no other lawful basis for which we may continue to process such information;
To the extent we are processing your Personal Information to meet our legitimate interests (as set out above), you may object to the processing of your Personal Information by us. If we are unable to demonstrate our legitimate grounds for that processing, we will no longer process your Personal Information for those purposes;
You may object to our processing as set out above;
You may withdraw any consent given to processing; or
Where we are processing your Personal Information automatically for the purposes of performing our contract with you, you may have the right to request that the Personal Information we hold about you be transferred to a third party data controller;
Where we may undertake automated decision-making we will request your explicit consent if the decision-making is not authorised by law or necessity for the performance of a contract.
You may also request that we restrict the processing of your data to that to which you have consented or for the establishment, exercise or defence of legal claims or the protection of the rights of another person, whilst we verify your data as set out in point 2 above; pending verification of our legitimate grounds as set out in point 4 above; or if the processing is unlawful or no longer necessary, but you wish us to retain your data for the purposes of establishing, exercising or defending legal claims.
Please contact GDPR@change-exchange.com and we will assist you and provide you with all rights to which you are entitled in relation to your Personal Information under applicable data protection law.
If you are unhappy with the way that we have handled your Personal Information, you can make a complaint to the Information Commissioners Office (ICO) which is the UK authority responsible for data protection. Contact details are available online, or alternatively please ask us on GDPR@change-exchange.com for assistance.