9-2-3 Jobs Limited (“9-2-3” or “we”) considers the privacy and security of your personal information to be very important. We are committed to protecting your privacy; we’ll only process your personal data where it is fair to do so, and to the extent that it is necessary for us to carry out our lawful business activities. If you would like to discuss this further, or have any questions, please don’t hesitate to contact us using the contact details set out at the bottom of this privacy notice.
In Annex 1 to this privacy notice, we explain what we mean by “personal data”, “processing” and other terms used in the notice.
What personal data do we process?
The personal data we collect may include your name, job title, employer and contact details, such as your telephone number and email address.
From where do we source this personal data?
The personal data which we process is obtained:
From you. We may obtain your personal data from telephone calls and other conversations between you and our employees, and from emails, letters or other documents which you send to us;
From your colleagues. We may also obtain your personal data from your colleagues, such as in circumstances where you are copied into emails, or where we are referred to you by another employee within your organisation;
Online. We may also obtain your personal data from your employer’s website or from employment-related networking websites such as LinkedIn;
From job advertisements. We may obtain your personal data from job advertisements which you or your employer have published or circulated
From industry events or groups. We may obtain your personal data from lists of names and/or contact details which may be circulated by organisers of industry events or groups to which you have contributed or in which you have participated;
From other places. We may obtain your personal data from your business card or from personal contacts.
For what purposes will we process your personal data?
To contact you initially. We may use your personal data for the purpose of contacting you to discuss whether we can assist you with seeking candidates to fill any current vacancies, and/or to discuss and share ideas and innovations relating to the flexible working movement;
To keep in touch with you. If you have expressed any interest in our services or in the flexible working movement generally, we may also use your personal data to contact you at annual intervals for the 5 years following our initial discussion, to check whether we can assist you with filling any vacancies and/or to share and discuss news, ideas and innovations relating to the flexible working movement;
To communicate with you and build our business relationship. We will also use your personal data for the purpose of communicating and answering enquiries generally, and for the purpose of building and maintaining our business relationship in a proper and efficient manner;
To invite you to participate in or contribute to our podcasts, social media posts or website content in the future;
To send you information about the flexible working movement, employment-related matters generally, industry news and updates, and information about our services and vacancies. If you have expressed any interest in our services or in the flexible working movement generally, we will also use your personal data for the purpose of sending you our electronic newsletter, containing information about our services, the vacancies we are seeking to fill, flexible working and employment-related matters, and news and industry updates. Each such communication will include an option for you to stop receiving future newsletters if you wish to do so. You can also of course ask us to stop sending you such newsletters at any time by using the contact details set out at the bottom of this notice.
Who is the data controller in respect of the personal data processed by 9-2-3?
9-2-3 is the ‘data controller’ of this information; we decide what your personal information is used for, and the ways in which it is processed. Our contact details are set out at the bottom of this privacy notice.
On what legal basis does 9-2-3 process my personal data?
The legal basis on which 9-2-3 processes your personal information is, in most cases, that of our legitimate interest.
However, if you are an individual (or otherwise acting for an organisation which doesn’t have a separate legal personality of its own, such as a partnership), then we will rely on your consent in order to process your personal information for the purposes of:
1. contacting you at annual intervals for the 5 years following our initial discussion, to check whether we can assist you with filling any vacancies and/or to share and discuss news, ideas and innovations relating to the flexible working movement; and
2. sending you our electronic newsletter, containing information about our services, the vacancies we are seeking to fill, flexible working and employment-related matters, and news and industry updates.
What is our legitimate interest in processing this personal data?
Establishment, maintenance and development of a business relationship. We think that we have a legitimate interest in using your personal data to seek to establish, develop and maintain a new business relationship with you as:
(a) a potential client; and/or
(b) a person or as a representative of an organisation whose campaigning, professional activities or industry-related news might be of general interest to our candidates, clients, website visitors and/or social media followers.
The storage of data about you as a business development contact is very important for this process and will be carried out on the basis of our legitimate interests. The making of contact with you at annual intervals in the future to offer to provide any assistance to you and/or to discuss ideas and news relating to, and developments in the field of, flexible working is also very important for this process. Where you are a representative of an incorporated organisation such as a company or LLP, this latter activity will also be carried out on the basis of our legitimate interests.
Inviting you to participate in our podcasts or social media posts. We believe that we have a legitimate interest in using your personal data to invite you to take part in the series of podcasts which we create, and/or the social media campaigns we run, as we seek to increase the amount of information which is available to the general public on flexible working and other employment-related matters; and
Keeping you updated. We have a legitimate interest in continuing to improve and grow as a business, in supporting and further developing our business relationship with you and, where you are a representative of an incorporated organisation such as a company or LLP, in seeking to keep you informed about our services, the vacancies we are seeking to fill, flexible working and employment-related matters, and news and industry updates; we therefore would like to send you our regular newsletter. However, each such newsletter will contain an option for you to stop receiving such newsletters if you would prefer to do so. You can of course also ask us to stop sending you such newsletters at any time by using the contact details set out at the bottom of this notice.
We will only use your personal data for our legitimate interests in circumstances where we have established that those legitimate interests are not overridden by your rights and freedoms.
For how long will we retain your personal data?
We will keep your personal data on our database for 5 years from the date on which we first record it, unless during this 5 year period you become a client, a podcast guest or a social media contributor. For further information about how we process the personal data of clients, podcast guests and social media contributors, please see our privacy notice menu.
With whom will your personal data be shared?
Your personal data may be shared with:
Consented parties. We may share your personal information in any circumstances where you have given your consent to such disclosure.
Law enforcement or regulatory bodies or agencies. If we receive a request from a regulatory or law enforcement body or agency, and if permitted by the GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
New business owners. If at any point in the future, 9-2-3 were to merge with or be acquired by another business or company, we may share your personal information with the new owners of the business or company and their advisors.
Third party suppliers of services to 9-2-3. These may include but are not limited to.
Software, database and cloud storage suppliers, including companies trading as Zoho, Google and Microsoft.
Squarespace Ireland Limited, our website host and data analytics provider.
IT support providers; and
Professional advisors including but not limited to HR advisors, lawyers and accountants.
We require minimum standards of confidentiality and data protection from these third party suppliers. The personal information which we collect may be transferred to and stored and processed in countries outside the EEA where our third party service providers have operations, including the United States. Such international transfers of your personal information will be made pursuant to appropriate safeguards, such as the EU/US Privacy Shield or the approved Model Clauses.
What happens if you visit our website?
Please note that if you visit our website, www.923jobs.com, then we will collect and process additional personal data relating to you. For further details, including information about what personal data we collect from visitors to our website and the purposes for which we process it, please see our web visitors’ privacy notice.
What rights do you have in relation to this processing of your personal data?
Your data protection rights include:
The right to be informed about the collection and use of your personal data;
The right of access to your personal data and the right to request a copy of the information we hold about you and supplementary details about it;
The right to have corrected any inaccuracies in the personal data we hold about you, including the right to update or add to the information we hold about you if you consider that it is incomplete;
The right to have personal data blocked, erased or destroyed in certain circumstances. For example, you might seek to exercise this right if we no longer needed to process your personal data for the purposes for which it was provided. This right is not absolute and we may not always be able to comply with your request, but please be assured that we will consider your request and our legal obligations in relation to it very seriously. More information about your right to have your personal data erased can be found here.
The right to object to, or to restrict, the processing of personal data under certain circumstances. For example, you might seek to exercise this right if any of the information we hold about you is inaccurate. This right is not absolute and we may not always be able to comply with your request, but please be assured that we will consider your request and our legal obligations in relation to it very seriously. More information about your right to object to our processing of your personal data can be found here.
The right to object to the use of your personal data for direct marketing purposes; if you let us know that you object to this use of your personal data, then we will of course stop using it for this purpose immediately. You can exercise this right using the contact details set out below, but each direct marketing communication which we send to you will also contain a link to enable you to stop receiving our newsletters.
The right to complain to the Information Commissioner’s Office (the “ICO”). If you have a concern about the way 9-2-3 has processed your personal data, you are entitled to lodge a complaint with a supervisory authority. In the UK, the supervisory authority is the ICO, who can be contacted here.
Further information about these rights generally is available here.
We’re sure that you will understand that we may require evidence of your identity before we are able to act on any request made in relation to the above rights.
Who should you contact if you wish to exercise your rights in relation to, or for further information about, this processing of your personal data?
If you would like to proceed in exercising these rights, or for further information about our processing of your personal data, please contact Lucy Haworth.
Annex 1: Meaning of Terms used in the Privacy Notice
“Personal data” is information relating to you, and from which you may be identified, which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you.
Data “processed automatically” includes information held on, or relating to use of, a computer, laptop, mobile phone or similar device. It could include sound and image data such as video recordings or photographs.
"Processing" means doing anything with the data. For example, it includes collecting it, holding it, disclosing it and deleting it.