1.1 Welcome towebsite. Anywhere “We”, “Us” and “our”, “Right Step Recruitment Ltd”, “the data controller”, “www.rightsteprecruitment.co.uk” is used in this document; it shall be referring to the company and the recruitment services provided through it.
1.3 The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) replaces the Data Protection Regulation (Directive 95/46/EC) from 25 May 2018. The Regulation aims to harmonize data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organizations can legally operate. Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1.5 We regret if there is any part of this policy that you are not happy about, your only recourse is to stop using the website.
1.6 Except as set out below, we do not share, sell or disclose any information collected through our website to a third party,.
2.1 Ris a reliable recruitment agency and recruitment business as defined in the Employment Agencies Act 1973 (our business). We also provide training, event organization and consultancy services from time to time.
2.2 The website is owned and managed by R. It is registered in London with the registration number 11223208
2.3 If you have any enquiry you can contact us at:
- Official email address: Info@rightsteprecruitment.co.uk
- Business Address: Kemp House, 152 – 160 City Road, London, EC1V 2NX
- Business Telephone: 0208 001 7393
3.0 Data Controller officer
3.1 The data controller for right step recruitment is the legal director and the address is as below: Kemp House, 152 – 160 City Road, London, EC1V 2NX
Our data protection declaration is legible and understandable for the general public, as well as our clients. To ensure this, we would like to begin by explaining the terminology used.
4.1 Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
4.2 Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing. The data subject here is “You”.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
4.4 Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
4.5 Data Controller or Controller responsible for the processing
This is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of data subject’s personal data. The details of our data controller can be found in section 3.
4.6 Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller and persons who, under the direct authority of the controller or processor, are authorized to have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signifies agreement to the processing of the personal data relating to them.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, centre, personal preferences, interests, reliability, behaviour, location or movements etc.
5.0 People we collect data from
5.1 Right Step Recruitment Ltd collects personal data from the following types of people to allow us to undertake our business:
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts (including referee contacts provided by candidates);
- Supplier contacts to support our services;
- Employees, consultants, temporary workers and contractors;
5.2 You may have applied directly to us or we may have found your details from a jobs board or social networking site. We are able to process your data if we have a legal basis for doing so.
5.3 There are six legal bases for processing data but we will rely on (1) your consent to send direct marketing messages about services other than our recruitment services, (2) that the processing is necessary for the performance of a contract with you, or (3) that we have a legitimate interest in processing your personal data.
6.0 The information we collect and how we collect
6.1 The information collected
6.1.1 Right step recruitment may collect personal information about you from the following sources:
- Contact information we receive from you, including your name, address, phone number, date of birth and email address, Visa and other right to work or identity information, Passport, Bank details, National insurance and tax (payroll) information, Next of kin and family details, Contact details of referees, Personal information relating to hobbies, interests and pastimes;
- Information about your educational level including qualifications, job history (including information relating to placements through us)work experience, education and skills set;
- Information contained in references and pre-employment checks from third parties;
- Information about your experiences with us when you respond to surveys or provide us with feedback;
- Non-personal data including your search history, IP Address, Operating System, geographical location, and account preferences and others.
- Other sensitive personal information such as health records (see ‘Sensitive Personal Data’ section below)
- Your marketing preferences
- You also authorize Right step recruitment to contact previous employers (where applied) and references, which may result in us obtaining additional personal information.
6.1.2 This information will only be collected when you voluntarily submit it to us, and you may visit our site anonymously.
6.2 How we collect your personal data
6.2.1 Right step recruitment may collect your personal data from the following, but not limited sources:
- You (e.g. a Curriculum Vitae, application or registration form)
- A client
- Other candidates
- Online jobsites
- Marketing databases
- The public domain
- Social Media such as LinkedIn
- At interview
- Conversations on the telephone or video conferencing (which may be recorded)
- Notes following a conversation or meeting
- Our websites and software applications
6.2.2 Where you are a Candidate and we have obtained your personal data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you.
7.0 How we use information collected
7.1 Right step recruitment may use the information collected from you in the following ways:
- To notify you of potential opportunities or roles
- To assess and review your suitability for job roles
- To introduce and/or supply you to actual or potential Clients
- To engage you for a role with us or with our Clients, including any related administration;
- To collate market or sector specific information and providing the same to our Clients
- To end information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services
- To provide information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
- To market our Recruitment Services
- Retaining a record of our dealings
- To customize the layout of our pages for each individual according to their preferences.
- Create a user account for you on www.rightsteprecruitment.co.uk
- and to offer nursing staffing services
8.0 How We Protect Your Information
8.1 We implement a variety of strict security measures to maintain the safety of your personal information.
8.2 Your personal information is contained behind secured CRM cloud based system and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
8.3 All sensitive/credit information you supply is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our databases to be only accessed as stated above.
9.0 Retention and Storage of Your Personal Information
9.1 Data retention
9.1.1 In most circumstances your data will not be retained for more than 6 years from the last point at which we provided any services or otherwise engaged with you.
9.1.2 It is our policy to retain your personal information for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purposes(s) remains valid even after termination of our relationship with you.
9.1.3 We may retain data for longer than a 6 year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, for example where your personal information identifies specialist skill sets which may remain in demand, or we are subject to a legal obligation which applies for a longer period.
9.1.4 If however you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons.
9.2 Storage of Your Personal Information
10.0 Erasure Or Removal Of Your Personal Data
10.1 The data controller shall process and store your personal data only for the period necessary to achieve the purpose of storage or as far as this is granted by the European legislator or other legislators in laws or regulations to which we or our agent is subject to
10.2 If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
10.3 You can delete your profile and its associated data at any time via your profile page or by emailing [Info@rightsteprecruitment.co.uk] and this will also remove all your information from the storage systems referenced above.
10.4 When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
11.0 Accessing and Updating Your Personal Information
11.1 We encourage you to correct and update information related to your account. Upon your request, we will provide you with any unique identifying or personal information that we maintain about you and will make any appropriate changes you provide us.
11.2 You can also contact us to:
- Close your account;
- Request a list of third parties to which Right step recruitment may have provided your personal information;
- Review the personal information held by us in connection with your account;
- Withdraw your consent for our use and disclosure of your information;
11.3 If you contact us to do any of the things listed above, we may require you to provide sufficient information to allow us identify you and tell you about the existence, use and disclosure of your Personal Information, and this Personal Information will only be used for this purpose.
11.4 If you contact us about your Personal Information, we will respond to your request within a reasonable time and at no cost to you.
12.0 What if we obtain your personal data from a third party?
12.1 Part of our business activity involves researching information for the purposes of finding and filling job roles. This may include obtaining personal data from sources including job boards, LinkedIn or other social media, some information being publicly available but others being from sites or providers to which we subscribe.
12.2 From time to time we may also receive personal data about you from hiring organizations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.
12.3 Where information from third party sources is of no use to us we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us for the provision of our Recruitment Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 17 ‘Your rights’.
13.0 International transfers of your personal data
13.1 In this Section 13, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA)].
13.2 The hosting facilities for our website are situated in the United States. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission
13.3 You acknowledge that personal data that you submit for publication through our Website or Services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
14.0 We do not collect Information From Children
14.1 Right step recruitment does not specifically direct any content to anyone below the age of 18. To use, you must be at least 18 years old.
15.0 Data Breaches
15.1 Right step recruitment will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
16.0 Information disclosure
16.1 Right step recruitment comply with the EU General Data Protection Right Act and do not sell, rent, transfer or exchange your personal information with any third party for business reasons. This does not include
- Candidates and other third parties, necessary for the provision of our Recruitment Services
- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
- Parties who process data on our behalf may include
- outsourced payroll providers
- IT support
- storage service providers including cloud providers
- background screening providers
- Legal and professional advisers
16.2 We may release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
16.3 Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
17.0 Your Rights
17.1 Right of confirmation
You have the right granted by the European legislator to obtain from Us, the controller or our agent, the confirmation as to whether or not the personal data concerning you are being processed. If you wish to avail yourself of this right of confirmation, you may, at any time, contact our Data Protection Officer or another employee of the controller.
17.2 Right of access
17.2.1 You shall have the right granted by the European legislator to obtain from Us, the controller free information about your personal data stored at any time and a copy of this information. The European directives and regulations grant you access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 15 of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
17.2.2 You shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
17.2.3 If you wish to avail yourself of this right of access, you may at any time contact our Data Protection Officer or another employee of the controller.
- Right To Rectification
The right to rectification is set out in Article 16 of the GDPR.
17.3.1 You shall have the right granted by the European legislator to obtain from Us, the controller without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
17.3.2 If you wish to exercise this right to rectification, you may, at any time, contact our Data Protection Officer or another employee of the controller.
17.4 Right to Erasure
17.4.1 You shall have the right granted by the European legislator to obtain from Us, the controller the erasure of personal data concerning you without undue delay, and we shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- You withdraw consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing;
- You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed; and
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
17.4.2 If one of the aforementioned reasons applies, and you wish to request the erasure of personal data stored by Right step recruitment, you may at any time contact our Data Protection Officer or third party agent. The Data Protection Officer of Right step recruitment or a third party controller shall promptly ensure that the erasure request is complied with immediately.
17.4.3 Where we have made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform our agents processing the personal data that you have requested erasure by such agents of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of Right step recruitment or any appointee will arrange the necessary measures in individual cases.
17.5 Right to object to processing
17.5.1 You shall have the right granted by the European legislator to obtain from Us, the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by you, for a period enabling Us to verify the accuracy of the personal data.
- The processing is unlawful and you oppose the erasure of the personal data and request instead for the restriction of their use.
- We no longer needs the personal data for the purposes of the processing, but are required by you for the establishment, exercise or defence of legal claims.
- You have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject. This must be notified to data subjects under Articles 21(4), 13(2)(b) and 14(2)(c)
17.5.2 If one of the aforementioned conditions is met, and you wish to request the restriction of the processing of personal data stored by Right step recruitment, you may at any time contact our Data Protection Officer or our third party agents. The Data Protection Officer of Right step recruitment or our third party agents will arrange the restriction of the processing.
17.6 Right to data portability
17.6.1 You shall have the right granted by the European legislator, to receive the personal data concerning you, which was provided to Us, in a structured, commonly used and machine-readable format. You shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 13(2)(b) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
17.6.2 In exercising your right to data portability pursuant to Article 20(1) of the GDPR, you shall have the right to have your personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
17.6.3 To assert the right to data portability, you may at any time contact Us or the Data Protection Officer designated by Right step recruitment
17.7 Right to object
17.7.1 You shall have the right granted by the European legislator to object, on grounds relating to your particular situation, at any time, to processing of personal data concerning you, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
17.7.2 Right step recruitment shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
17.7.3 If Right step recruitment processes your personal data for direct marketing purposes, you shall have the right to object at any time to processing of your personal data for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If you object to Right step recruitment to the processing for direct marketing purposes, Right step recruitment will no longer process the personal data for these purposes.
17.7.4 You have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you by Right step recruitment for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
17.8 Right to withdraw consent
17.8.1 You shall have the right granted by the European legislator to withdraw your consent to processing of your personal data at any time.
17.8.2 If you wish to exercise the right to withdraw the consent, you may at any time directly contact our contact Right step recruitment or our Data Protection Officer
17.9 Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken to both evidence our compliance, and to take steps to minimize the prospect of any data being processed in the future should it be received again from a third-party source.
If you have any questions concerning your rights or should you wish to exercise any of these rights please contact: [Harris Zaidi – Tel: 0208 001 7393 E-mail: Harris.Zaidi@rightsteprecruitment.co.uk]
18.0 Compliance With Laws And Law Enforcement
18.1 Right step recruitment cooperates with government and law enforcement officials. We reserve the right to share any information we have about you with government or law enforcement officials if need be.
18.2 The decision to share this information will be at the sole discretion of Right step recruitment to protect the property and rights of Right step recruitment or a third party or the personal safety of any person or to prevent any illegal unethical or legally actionable activity or to comply with the law in any other way.
19.0 Email communications
19.1 If you have opted-in to receive our e-mail newsletter, Right step recruitment may send you periodic e-mails.
19.2 If you would no longer like to receive promotional e-mail from us, please refer to the “How can you opt-out, remove or modify information you have provided to us” section below.
19.3 If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails.
20.0 Cookies, cookies we use and Managing cookies
20.1.1uses the “cookie” technology.
20.1.2 A cookie is a little piece of text stored by the browser on your computer, at the request of our server.
- Make our website work as you’d expect
- Remember your settings during and between visits
- Improve the speed/security of the site
- Monitor user traffic patterns
- Understand how our visitors use our website
- Make our marketing more efficient
20.2 The cookies we use
The cookies we use are as follows:
20.2.1 Strictly necessary
Just as it says, these are the essential cookies to enable you to use the site effectively i.e. applying for a job or submitting a CV. Accepting these cookies is a condition of using the site
These cookies help our site remember the choices you made, for example, username, and also help make the most of our enhanced features, such as providing news or updates relevant to you.
These cookies help us monitor the performance of our site, providing us with the information to constantly optimise and develop our site to get the best user experience for you, for example site visits or source of visitors.
We use personalisation or targeting cookies to make sure we advertise the jobs that we think may be of interest to you, making your user experience a personalised one.
20.2.5 Third party
As you use our site, you will notice that we have content from other sites, for example, YouTube or Google Maps. We also facilitate the opportunity to engage with us further through social media channels, for example Twitter and Facebook. We use third party cookies to help deliver relevant information to you and integrate content with social networks.
20.2.6 Google Analytics
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
20.2.8 If you don’t want us to store a cookie on your PC to make your journey on our website the best it can be, you can switch cookies off by adjusting your browser settings to stop it from accepting cookies.
20.3 Managing cookies
20.3.1 If you choose to disable cookies, you will not be able to use some of the key functions of Right step recruitment website including:
- Registering with www.rightsteprecruitment.co.uk
- Signing in to www.rightsteprecruitment.co.uk
- Applying for jobs on www.rightsteprecruitment.co.uk
- Submitting a CV
20.3.2 To disable cookies, go to “Options” under “Tools” menu. You can also use the ‘Help’ option in your browser for more details. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
20.3.3 Blocking all cookies will have a negative impact upon the usability of many websites.
20.3.4 If you block cookies, you will not be able to use all the features on our website.
21.0 Legal basis for the processing
21.1 Art. 6(1) lit. (a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.
21.2 If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, when processing operations are necessary for consultation or coaching, the processing is based on Article 6(1) lit. (b) GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries about our coaching and consultation services.
21.3 If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing will be based on Art. 6(1) lit. (c) GDPR. In exceptional cases, the processing of personal data may be necessary to protect your vital interests.
21.4 Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator.
22.0 Opting Out
22.1 At any time you can unsubscribe from Right step recruitment emails using the unsubscribe links contained in any email that we send you or by contacting us at [firstname.lastname@example.org] or call [0208 001 7393]
23.0 Policy Acceptance
23.1 By using, you understand that you are not under any force to provide your personal information. Any personal information provided is with your full permission, and desire to provide such personal information.
23.2 Right step recruitment is not under any obligation to verify the source from which the personal information is provided, and are considered to be provided by you, except they prove within a period of 15 days from the date of providing such information to Right step recruitment’s contentment that the information was provided without their free consent.
24.0 Policy Update
24.3 Users are advised to periodically check this page to be sure they are familiar with any changes.
25.1 If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to: [email@example.com]. This does not affect your right to make a complaint to the Information Commissioner’s Office.