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”, “special category personal data” and other terms used in the notice.
What personal data do we process?
The personal data we process may include:
Basic details. This may include your name, date of birth, home address, telephone number and email address;
Information about your training, qualifications and experience. This may include any personal data provided by you as part of your curriculum vitae, any registration data or certificate issued or published by a professional regulatory body, documentary evidence of your training, qualifications, experience and/or authority to undertake particular work, details of the ways in which you fulfil any legal, regulatory or client requirements for the performance of a particular role, and copies of references provided to us concerning you;
Records of conversations with you. These may include, for example, records of our conversations with you about your work preferences and/or requirements and any other information you mention to us relating to your search for employment;
Information relating to your right to work in the UK. This may include but isn’t limited to a copy of your passport and notes of our interview with you concerning this passport;
Records of introductions and engagements. This may include records of any introduction/s we have made of you to any client/s of 9-2-3, records of any engagement/s of you by any client/s of 9-2-3, and the terms of such engagement/s, including details of your pay, benefits, pension entitlements and pension contributions;
Special category personal data. In addition, it is possible that we may from time to time process special category data including but not limited to information concerning your health or any disability you experience. This is relatively rare but such processing may take place if, for example, you have a health condition or disability which is relevant to the type of role, or specific roles, you are interested in pursuing, or relevant to interview arrangements, or of which you wanted us to make an interviewer aware for any other reason.
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, from emails, letters or other documents which you send to us, and from details which you submit to us via the candidate registration page on our website, at www.923jobs.com/candidates;
From third parties. We may obtain your personal data from the providers of references concerning you, and/or from professional or regulatory bodies who may provide details of your professional qualifications or registrations, or of your authorisation to undertake particular types of work; and
Online. We may also obtain your personal data from employment-related websites on which you may have specified that you are seeking work (including but not limited to LinkedIn).
For what purposes will we process your personal data?
We may process your personal data for the purposes of:
1. Finding you new roles. We may process your personal data for the purpose of matching you with and introducing you to potentially suitable employers who are seeking to fill vacancies, and storing your personal data on our database to enable us to match you with and introduce you to potentially suitable employers who may be seeking to fill vacancies in the future;
2. Communicating with you. We may process your personal data for the purpose of ensuring the proper and efficient operation and maintenance of our business relationship, and of communicating with you and answering enquiries. In practice, this may include but is not limited to discussing particular vacancies as and when they arise, arranging interviews, discussing the terms of any employment offer, confirming arrangements for you to start work pursuant to an acceptable offer, checking that the placement is progressing well at appropriate intervals after you have commenced working for a new employer, and checking whether you want to remain on our database and receive emails about our vacancies and services;
3. Keeping you updated. We may process your personal data for the purpose of sending to you our electronic newsletter, and/or other emails, containing information about our services, the vacancies we are seeking to fill, flexible working and employment-related matters, and/or news and industry updates. Such newsletters may also contain information about events, courses, activities and/or other services offered by third parties. Each such communication will include an option for you to stop receiving future newsletters or emails about the services we offer. You can of course also ask us to stop sending you such newsletters and emails at any time by using the contact details set out at the bottom of this notice;
4. Complying with legal obligations. We may process your personal data for the purpose of complying with our legal obligations under, for example, The Conduct of Employment Agencies and Employment Businesses Regulations 2003 and/or the Equality Act 2010, and where we are required to do so, disclosing your personal data to law enforcement or regulatory agencies; and
4. Legal claims. We may process your personal data for the purpose of establishing, bringing or defending any legal claims.
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 that of:
1.The fulfilment of our legal obligations. The circumstances in which this legal basis will apply include, but are not limited to, the following:
(i) When we provide services to you, we are legally obliged to hold certain information on you, and to retain copies of relevant documents, which may include your personal data;
(ii) If you consent to our introduction of you to a potential employer, we may also be legally obliged to disclose to the potential employer some of your personal data. In rare circumstances, our legal obligations may also mean that we are required to process and disclose to a potential employer certain types of your special category data. In such cases, our legal obligations will form the legal basis of such processing and disclosure; and
(iii) When we provide services to you, we must ensure that we comply with the Equality Act 2010;
(iv) We may also under certain circumstances be obliged to disclose your personal data to a regulatory body or law enforcement agency; and
2. Consent. Specifically, we use consent as the legal basis for:
(i) storing, reviewing and using any personal data and/or any special category personal data which you have provided to us and which we are not required by law to store, in order to match you with potentially suitable vacancies at the time of your initial registration with us or in the future and in order to communicate with you. Such personal data might include, but is not limited to, your telephone number and email address and details of your work preferences or requirements;
(ii) storing, reviewing and using, any personal data and/or any special category personal data which we hold on you for longer than 12 months after we last provided any services to you in order to match you with potentially suitable vacancies in the future and in order to communicate with you;
(iii) passing your personal data, and potentially some types of special category personal data, to potential employers; we will only usually do this with your explicit consent in relation to each individual vacancy. However, please note that as mentioned above, if we introduce you to a potential employer then there may be some types of your personal data, and potentially some types of your special category personal data, which we are legally obliged to disclose to the potential employer. Where this is the case, the legal basis for the sharing of such information with the potential employer will be our legal obligation; and
(iv) sending you our electronic newsletters, and/or other emails, containing information about our services, the vacancies we are seeking to fill, flexible working and employment-related matters, and/or news and industry updates. Such newsletters may also contain information about events, courses and/or other services offered by third parties.
If we need to rely on consent as the legal basis for processing any other categories of your personal data, we will very clearly ask for your permission; and
3. Our legitimate interests. This will form the legal basis of our processing of your personal data in order to:
(i) contact you at appropriate intervals to check whether you wish to remain on our database and whether you wish to continue receiving emails about our vacancies, services, flexible working and employment-related matters, and/or news and industry updates; and
(ii) establish, bring or defend any legal claims which may be necessary from time to time.
On what legal basis does 9-2-3 process sensitive personal data about you?
If we process sensitive personal data about you, as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one or more of the grounds for processing sensitive personal data applies. In outline, these include:
Processing being carried out because you have given your consent to such processing for a specified purpose;
Processing being necessary for the purposes of your or our obligations and rights in relation to employment or social protection in so far as it is authorised by law; and
Processing being necessary for the purpose of establishing, making or defending legal claims.
What is our legitimate interest in processing this personal data?
We consider that we have a legitimate interest in processing your personal data in order to contact you at appropriate intervals to check whether you still wish to remain on our database and whether you wish to continue receiving emails about our vacancies, services, flexible working and employment-related matters, and/or news and industry updates. It’s true that we have a legal obligation to hold on to certain items of your personal information for the 12 months after we last provided services to you. However, subject to this legal obligation, we want to make sure that we are not holding on to your personal information for longer than you want us to do so; we don’t think that this would be fair, and we want to make sure that we treat our candidates’ data as we would like our own data to be treated. We think that this is a fair and reasonable step which will enable us to check whether you are happy for us to continue to process your personal data.
We also consider that we have a legitimate interest in processing any data necessary to bring, establish or defend any legal claims as necessary from time to time.
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 for an initial period of 12 months after we last provided any services to you (such as, for example, introducing you to a potential employer). We will then contact you:
1. upon the expiry of this initial 12 month period; and
2. every 12 months thereafter
to ask whether you wish to remain on our database, and whether you also wish to continue receiving our newsletters and other emails about our services, until such time as you confirm that you do not wish to do so, or we do not receive a response from you. At this point we will remove you from our database and/or stop sending you our newsletters and emails about our services, as appropriate.
With whom will your personal data be shared?
Your personal data may be shared with:
Clients. We may share your personal data, and potentially your special category personal data, with clients who have vacancies in which you are interested, for the purpose of seeking to find you new employment;
Other consented parties. We may also share your personal information in any other 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;
Government bodies and agencies. This may include HMRC and the Employment Agency Standards Inspectorate;
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 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 email which we send to you will also contain a link to enable you to stop receiving such communications.
The right to receive any information we hold about you in a machine-readable, structured, and commonly-used format. You can also ask us to send this information directly to a third party organisation if you would prefer to do so. This right only applies in certain circumstances; for example, it will only apply to personal data in relation to which we have clearly requested, and you have given, your consent for processing.
The right to withdraw consent. Where we have requested your consent to carry out any processing of your data, you can of course withdraw your consent at any time;
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.
“Special category personal data” means personal data revealing or concerning an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership, genetic and biometric data.