In this Annex we explain how KACD Limited t/a London Recruitment Agency manages your personal data. 

1       Collection and use of personal data

1. Purpose of processing and legal basis

London Recruitment Agency will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients. 

In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

The legal bases we rely upon to offer these services to you are:

• Your consent 
• Where we have a legitimate interest 
• To comply with a legal obligation that we have
• To fulfil a contractual obligation that we have with you

• Legitimate interest 

This is where London Recruitment Agency has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.  Where London Recruitment Agency has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• Employment opportunities – Providing work-finding services to the individual, including sending their information to your clients where they have demonstrated an interest in doing that particular type of work but not expressly consented to you passing on their cv; 
• Managing your database and keeping work-seeker records up to date; 

• Recipient/s of data

London Recruitment Agency will process your personal data and/or sensitive personal data with the following recipients:

•  Crystal Joyce Furman/ Director CEO  

• Statutory/contractual requirement

Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:

• Loss of employment opportunities 

2       Overseas Transfers [Optional]

London Recruitment Agency may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. 

3       Data retention

London Recruitment Agency will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. 

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.

Where London Recruitment Agency has obtained your consent to process your personal and sensitive personal data/passport, proof of address], we will do so in line with our retention policy (a copy of which is attached). Upon expiry of that period London Recruitment Agency will seek further consent from you. Where consent is not granted London Recruitment Agency will cease to process your [personal data/[and] sensitive personal] data].

4       Your rights 

Please be aware that you have the following data protection rights:

• The right to be informed about the personal data London Recruitment Agency processes on you;
• The right of access to the personal data [Insert agency name] processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.

Where you have consented to London Recruitment Agency processing your personal data/[and]sensitive personal data] you have the right to withdraw that consent at any time by contacting Crystal Joyce Furman who handles data protection issues and, where applicable, any representative of the controller and the data protection officer. 

There may be circumstances where London Recruitment Agency will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons. 

If you believe that any of your data that London Recruitment Agency processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary. 

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

5       Automated decision-making 

London Recruitment Agency may outsource licensed verifiers and will provide meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the individual. 

6       Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact:

Crystal Joyce Furman, London Recruitment Agency Director who handles data protection issues and, where applicable, any representative of the controller and the data protection officer. 

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.

If, during the course of a temporary assignment, the Client wishes to employ me direct, I acknowledge that London Recruitment Agency will be entitled either to charge the client an introduction/transfer fee, or to agree an extension of the hiring period with the Client (after which I may be employed by the Client without further charge being applicable to the Client).