Group SRS Privacy Policy 2018-06-06T12:16:43+00:00

Group SRS Privacy Policy

Who are we?

The data controller is Group SRS based at 38 Washington Street, G3 8AZ. We are a recruitment agency, care company and training company providing staff across multiple sectors. As data controller, we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

Who does this apply to?

This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers, Service Users and other people whom we may contact in order to find out more about our Candidates. You can find our definitions of the above terms at the bottom of this page.

It is important to note that we make amendments to this policy periodically, so please ensure you check this page from time to time as all policy amendments/updates will be posted here.

What does this Privacy Policy cover?

At Group SRS, we take your data seriously. In this policy, you can find out:

  • The types of personal data we collect about you

  • The reasons how and why we collect and process your personal data

  • How long we hold your personal data for

  • Who we share your data with and the reasons why

  • Our legal basis for using your personal data

What personal data do we collect about you?

Candidates

In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only collect and use only the essential information to be able to find the best available opportunities and any further information needed to assess your eligibility through the different stages of the recruitment process. This information includes:

  • Your name, address and contact details including your mobile/home number and email address.

  • Details and information regarding your employment/education history, skills, experience, relevant qualifications and references.

  • Whether you have a disability to ensure you still receive the opportunity for an interview if you meet the minimum criteria for the post.

  • Information regarding your eligibility to legally work within the UK.

  • Your national insurance number

  • Your membership number for organisations such as the SSSC and PVG.

  • Information regarding any disciplinary action against you at previous places of employment.

  • If you have any close friends or family members who Group SRS provide services to.

  • Details regarding any criminal convictions you may have against you.

  • Information you supply us with regarding your personal qualities such as your supporting statement.

Group SRS  may collect the above information in various ways. Such data may be contained within application forms, CV’s/resumes, obtained from a passport or another personal identity document, or collected through digital/face-to-face  interviews and other forms of assessment.

Clients

We collect and use only the information necessary to provide you, or people in your organisation with services such as finding the best available candidates for your opportunities.

The data we collect on candidates is limited in comparison to the data we require from candidates. Generally, we only need to have your contact details or the details of individual contacts at your organisation (such as their names, phone numbers and email addresses) to enable us to ensure that our relationship runs smoothly, and to ensure that we can contact you at any given time.

Suppliers

We don’t require much data to be collected from suppliers. We require relevant contact information from individuals at your organisation in order to communicate with you. We also require information such as your bank details so we can make payments for any services or products you provide (if this is part of a contractual agreement).

Website Users

When you use our website, we may collect personal data regarding yourself and your usage of the website. We may collect information you provide through online application forms, contact forms and through the use of website cookies.

Cookies are a small text files that are stored in your web browser that allows Group SRS or a third party to recognize you. Cookies can be used to collect, store and share certain information about your activities across websites, including on Group SRS’s website.

Cookies might be used for the following purposes:

  • To enable certain functions

  • To provide analytics

  • To store your preferences

  • To enable ad delivery and behavioral advertising

When someone visits any of our websites, we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site and to improve the design and content of our websites. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website

If you don’t like the idea of cookies or certain types of cookies, you can change your browser’s settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser.

Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Service Users

We collect information about you which is relevant to helping us provide you with the most suitable care plan:

  • Personal details (such as your name, date of birth, gender, marital status, national insurance number)

  • Contact details (such as your previous address, phone number and email address)

  • Financial information (such as your bank account details and information about your financial circumstances)

  • Preferences and your likes and dislikes (such as favourite hobbies/pastimes, diet, routines and other categories of likes and dislikes which help us provide a custom-tailored care plan)

  • Information about your care preferences (to ensure that we are providing you with the type of care best for your needs);

  • Details of your life history (to ensure that we can help provide you an environment where you feel at home);

  • Information about your family and friends (for emergency contact information);

  • Information about external healthcare providers (such as your GP and practice details);

  • Healthcare information (such as disabilities, medical records, dietary requirements etc..)

  • Video and photos of you (such as CCTV footage, photographs for security purposes, etc)

  • Information about your long term wishes (such as your desired arrangements in the event that you pass away while under our care)

What if I don’t want my data processed and stored?

Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfill our contractual requirements or, in extreme cases, may not be able to continue with our relationship. An example of this may be a candidates refusal to provide necessary information within an application form. In this case, the candidate may no longer be able to work under Group SRS. Group SRS is also legally compelled under Safer Recruitment guidance to hold and process information on potential candidates and staff that work for us.

How do we collect your personal data?

Candidates

There are two primary ways in which we collect your personal data:

  1. Directly from you

  2. From third parties

  3. Automatically

Directly from you

Group SRS requires certain information from you in order to provide a tailored service to yourself.  This information you provide us with will help us provide you with the best and most relevant job opportunities available. There are various ways in which you can share information with us:

  • Entering your details on one of the Group SRS websites or via an application form, as part of the registration process.

  • Leaving a hard copy CV at a Group SRS recruitment event, job fair or office

  • Emailing a digital copy of your CV to a Group SRS consultant or by being interviewed by them

  • Applying for jobs through a job aggregator, which then redirects you to the Group SRS website

  • Entering a competition through a social media channel such as Facebook or LinkedIn or our website.

Third parties

We may also receive data about candidates from third party sources. Subject to local laws and relevant circumstances, this data may be provided in some of the following ways:

  • Your referees may provide certain personal information regarding yourself

  • Our clients may disclose certain information about you with us

  • We may obtain personal information about you from third party websites such as LinkedIn and job boards while searching for candidates

  • If you follow us on social media channels or “like” our Facebook page or social media posts, we will receive your personal information

Data we collect automatically

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.

Clients

We collect your information in two different ways:

  1. Directly from you

  2. From third party sources (candidates and other sources such as websites and offline media)

To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us. Please refer to our Cookies section for more information regarding this.

Directly from you

We collect data directly from you in two different scenarios:

  • When you contact us, usually by email or by phone

  • When we contact you, usually by email or by phone

Third party sources

Where appropriate and in accordance with any local laws and requirements, we may seek further information regarding you or your colleagues from other sources generally by way of due diligence or other market intelligence including:

  • From third party market research and by analysing online and offline media

  • From delegate lists at relevant events;

  • From other limited sources and third parties (for example from our candidates to the extent that they provide us with your details to act as a referee for them)

Suppliers

We collect your personal data during the course of our work with you.

To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us. Please refer to our Cookies section for more information regarding this.

Individuals data who we receive from candidates and staff such as a referee or emergency contact

We collect your contact details only where a Candidate or a member of our Staff puts you down as their emergency contact or where a Candidate gives them to us in order for you to serve as a referee.

Website Users

We collect your data automatically using website cookies. Please refer to the Cookies section for more information regarding this. We will also collect information you willingly submit to us through the website such as data and information you provide via a contact form.

Service Users

We obtain your information in multiple ways:

  • Directly from yourself  

  • From friends and relatives who provide us with information

  • From anyone who has the authority to act on your behalf

  • From healthcare professionals in the local authority/social services department

How do we use your personal data?

Candidates

Once we have obtained your personal data, we may use this data in a number of ways which include:

  • Recruitment activities

  • Marketing activities

  • To aid us in the event of a legal claim

Recruitment Activities

At Group SRS, our main objective is to connect candidates with the right jobs. Listed below is a non-exhaustive list of ways in which we may use and process your data for recruitment activity purposes:

  • Storing your details (and updating them when necessary) on our database, so that we can contact you with relevant job opportunities and clients

  • Providing you with our recruitment services and to facilitate the recruitment process

  • Sending your information to clients, in order to apply for jobs or to assess your eligibility for suitable jobs

  • Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you

  • Allowing you to participate in the interactive features of our services, when you choose to do so

  • Carrying out our obligations arising from any contracts entered into between us

  • Carrying out our obligations arising from any contracts entered into between Group SRS and third parties in relation to your recruitment

  • Facilitating our payroll and invoicing processes

  • Carrying out customer satisfaction surveys

  • Verifying details you have provided or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws)

  • Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties

  • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you

We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you want to know more about what this means, please click here. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this here.

Marketing Activities

We may periodically send you information and job vacancies that we think you may find interesting and relevant. Listed below are some purposes in which we may contact you with marketing material:

  • To market our range of recruitment services (permanent, temporary, contract etc…)

  • Send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you

  • display promotional excerpts such as endorsements and success stories from your details on Group SRS’s website such as a success story (only where we have obtained your express consent to do so)

  • provide you with information about certain discounts and offers that you are eligible for by virtue of your relationship with Group SRS

We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in (which we explain further below).

Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types online marketing, we are required to obtain your explicit consent.

Legal Claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

Clients

Once we have obtained your personal data , we may use this data in a number of ways which include:

  • Recruitment activities

  • Marketing activities

  • To aid us in the event of a legal claim

Recruitment activities

  • Keeping records of our conversations and meetings, so that we can continue providing targeted services to you

  • Undertaking customer satisfaction surveys

  • Processing your data for the purpose of targeting appropriate marketing campaigns

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to know more about what this means, please click here. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this here.

Marketing activities

Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as promotional leaflets about our services to a corporate postal or email address. If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about this here.

Legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

Suppliers

We understand that you likely won’t want us contacting you very often. As such we will only use your information:

  • To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;

  • To offer services to you or to obtain support and services from you

  • To perform certain legal obligations

  • To help us to target appropriate marketing campaigns

  • In more unusual circumstances, to help us to establish, exercise or defend legal claims.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.If you want to know more about what this means, please click here. If you are not happy about this, in certain circumstances you have the right to object and can find out more about this here.

Individuals data who we receive from candidates and staff such as a referee or emergency contact

We will only use your information provides to us by staff or candidates in the following circumstances:

  • If our candidates or staff members put you down on our form as an emergency contact, we’ll contact you in the case of an accident or emergency affecting them

  • If you were put down by our candidate or a prospective member of Staff as a referee, we will contact you in order to take up a reference. This is an important part of our recruitment process, and could be the difference between the individual getting a job or not.

  • If you were put down by our candidate or a prospective member of staff as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of clients.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to find out more about what this means, please click here. If you are not happy about this, you have the right to object and can find out more about how to do so here.

Website Users

We may use your data to help improve your experience of the website. For example, analysing recent job search history on our website in order to help serve you relevant vacancies that may be of interest to you.  

Service Users

We collect your information to provide you with a safe, appropriate and personalised care plan and suitable accommodation to suit your personal requirements. We also collect your information for communication purposes so we may contact you at various times while you are under our care plan. Your information is also collected to handle events in the case of a complaint, and for administration and finance purposes such as to take payments. We are also required by external care bodies such as the SSSC and the Care Inspectorate to hold and maintain up to date information regarding all service users.

Who do we share your personal data with?

Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

  • Any of our group companies such as SRS Partnership, SRS Care Solutions and SRS Training

  • Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies

  • Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation)

  • Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants and IT consultants.

  • Marketing technology platforms and suppliers

  • In the case of candidates: potential employers and other recruitment agencies/organisations to increase your chances of finding employment

  • In the case of candidates: third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job

  • If Group SRS merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

How do we protect your personal data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures that are contained within the company’s policy handbook given to every employee of Group SRS. These include measures to deal with any suspected data breach.

How long will we keep your personal data for?

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 two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.

For those candidates whose services are provided via a third party company or other entity, “meaningful contact” with you means meaningful contact 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 retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.

When we refer to “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 take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

Our legal basis for processing your data

Article 6(1)(f) of the GDPR is the one that is relevant here – it says 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.”

We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please click here.

Candidate Data

  • We think it’s reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our range of vacancies. Once it’s looking like you may get the job, your prospective employer may also want to double check any information you’ve given us or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other candidates get the jobs you deserve.

  • We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.

  • We have to make sure our business runs smoothly, so that we can carry on providing services to candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.

  • We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.

Client Data

To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.

Suppliers Data

We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a customer of your services.

Individuals data who we receive from candidates and staff such as a referee or emergency contact

  • If you have been put down by a candidate or a prospective member of staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.

  • If a candidate or staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.

Service Users

We collect your information to provide you with safe, appropriate and personalised care plan and suitable accommodation to suit your personal requirements. We also collect your information for communication purposes so we may contact you at various times while you are under our care plan. Your information is also collected to handle events in the case of a complaint, and for administration and finance purposes such as to take payments. We are also required by external care bodies such as the SSSC and the Care Inspectorate to hold and maintain up to date information regarding all service users. We deem all such activities necessary within the range of our legitimate interests.

Transferring your data outside the EU

In order to properly process your data in an organised and secure manner, your data may be transferred to a third party service located outside the EU. Group SRS use a cloud based storage service based in Canada to securely store your data that is fully compliant with data protection regulations. Our cloud storage is also set up with end to end encryption, password protected files and variable access levels for appropriate employees to ensure personal data is completely secure and is only viewable by those authorised.

Consent

In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.

Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.”  What this means in plain language:

  • you have to give us your consent freely, without us putting you under any type of pressure

  • you have to know what you are consenting to – so we’ll make sure we give you enough information

  • you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion. For example, a checkbox under an SRS mailing list form which you can tick if you want to opt-in to receive newsletters.

We will keep records of the consents you have given in this way.

We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications. As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time by emailing ewan@groupsrs.com. 

Your Rights

By law, you have a number of rights when it comes to your personal data.

  • The Right to be Informed –  You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Policy.

  • The Right of AccessYou have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection laws.

  • The Right to RectificationYou are entitled to have your information corrected if it’s inaccurate or incomplete.

  • The Right to ErasureThis is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

  • The Right to Restrict Processing –  You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

  • The Right to Data PortabilityYou have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

  • The Right to Object to ProcessingYou have the right to object to certain types of processing, including processing for direct marketing.

  • The Right to Lodge a ComplaintYou have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

  • The Right to Withdraw ConsentIf you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or

  • further copies of the same information

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that Group SRS transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing at 119 Pentagon Centre, 38 Washington Street.

Definitions

Candidates

Includes applicants for all roles advertised or promoted by Group SRS, including permanent, part-time and temporary positions and freelance roles with Group SRS’s clients; as well as people who have supplied a speculative CV to Group SRS not in relation to a specific job.

Clients

This covers our customers, clients, and others to whom Group SRS provides services in the course of its business.

Delete

While we will endeavor to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or staff. When we aim to permanently erase data, all hard copies of personal data will be shredded and digital data will be permanently erased from all systems.

GDPR

A European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.

Website User

Any individual who accesses any of SRS Group SRS’s website.

Supplier

Refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Group SRS.

Service User

An individual who SRS Care Solutions are providing a care plan to.