9-2-3 Jobs Limited
Privacy Notice: Client contacts
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, your telephone number and email address.
If you are instructing us in an individual capacity, rather than on behalf of an employer, we may also hold further personal data relating to you, including your home address, and the nature of your business.
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, or from forms which you have filled in and submitted to us on our website, https://www.923jobs.com/why-9-2-3;
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, from our use of online search engines including Google, from job vacancy notification websites such as boiler, 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; and
From other places. We may obtain your personal data from your business card or from personal contacts.
Are you contractually obliged to provide this personal data?
Under our terms of business, if you instruct us in your individual capacity, you will need to provide details of your identity, the nature of your business and the location at which the relevant role must be carried out, which may be your home address.
For what purposes will we process your personal data?
To provide recruitment services to you, to communicate and answer enquiries, and to ensure the proper and efficient operation and maintenance of our business relationship. In practice, such purposes may include but are not limited to contacting you to discuss new or ongoing vacancies, discussing and sending you information about potential candidate matches, arranging interviews, discussing the terms of any offer to a candidate and arrangements for a candidate to start work, submitting an invoice to you once a placement has been made, checking that all is progressing well with your new employee once a placement has been made, and arranging a refund if you are entitled to one upon the termination of a placement.
To invite you to speak on a podcast or at an event, or to contribute to a social media post in the future.
To send you information about the flexible working movement, employment-related matters generally, industry news and updates, information about our services and information about the vacancies we are seeking to fill. 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.
To keep in touch with you. We may also use your personal data to contact you at annual intervals for the 5 years following the date on which we last provided services to you, to check whether we can assist you with filling any vacancies.
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 the Equality Act 2010, and where we are required to do so, disclosing your personal data to law enforcement or regulatory agencies.
Processing in order to demonstrate compliance with the terms of our contract and in relation to legal claims. We will also retain and potentially use and/or disclose copies of emails and documents relating to a placement to ensure we are able to demonstrate that we have complied with the terms of our contract with you or your employer. Such retention is also necessary to ensure that in the event of any legal claim, we have access to copies of relevant documentation. We may also 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 bases on which 9-2-3 may process your personal information are:
1. the performance of our contract with you (if you are instructing us as an individual, rather than on behalf of your employer);
2. our legitimate interests; and/or
3. the fulfilment of our legal obligations. For example, when we provide services to you, we are legally obliged to hold certain information on you or your organisation and to retain copies of relevant documents, which may include your personal data. We may also under certain circumstances be obliged to disclose your personal data to a regulatory body or law enforcement agency.
What is our legitimate interest in processing this personal data?
We consider that we have a legitimate interest:
1. in using your personal data in the day to day running of our business. As a recruitment agency, our core business activity is the introduction of suitable candidates to clients to fill employment vacancies. The storage of data about individual clients, or about the employees of client organisations and companies, is essential for this process. In order to manage our business affairs and provide the best possible service to our clients in sourcing suitable candidates to fill their employment vacancies, we need to retain a database of our client contacts, their email addresses and telephone numbers and present and historical resourcing requirements. To ensure the efficient and proper operation of the agency-client relationship, we also need to be able to contact the most suitable member of the client team to discuss vacancies and candidates, make arrangements for interviews, discuss the terms of job offers, send invoices, and ensure that a placement has proceeded smoothly or arrange any necessary refunds;
2. in 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 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;
3. in keeping in touch. We have a legitimate interest in seeking to keep in touch with you and in developing our business relationship with you. We therefore would like to contact you at annual intervals in the future to ask whether we can provide any further assistance with filling any vacancies which you may have at that time;
4. In demonstrating compliance with the terms of our contract and in processing personal data in order to ensure that we can establish, make or defend legal claims. We have a legitimate interest in retaining (and potentially using and/or disclosing) emails and documents relating to a placement, in order to ensure we can demonstrate that we have complied with the terms of our contract with you or your employer, and in order to ensure that in the event of any legal claim, we have access to copies of relevant documentation. We also 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?
In general, we will keep your personal data until the later of:
(a) 6.5 years after the last date on which a 9-2-3 candidate started working for you or your employer; or
(b) 5 years after the last date on which a 9-2-3 candidate was introduced to you or your employer.
Please note however that if we needed to bring or defend a legal claim at any point in the future, and we needed to process your personal data in connection with this claim, then we would continue such processing until the later of:
1. 6.5 years from the last date on which a 9-2-3 candidate started working for you or your employer; and
2. the date on which all matters relating to that legal claim had been finalised.
With whom will your personal data be shared?
Your personal data may be shared with:
Candidates. We may share your name and job title with a candidate who is meeting with you for an interview, so that both you and the candidate can derive the maximum benefit from the time allocated to the interview. In the unlikely event that we were involved in any legal dispute with a candidate, we might also need to disclose your personal data to that candidate in order to defend ourselves against any legal claim;
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, or courts. If we receive a request from a regulatory or law enforcement body or agency, and if permitted by UK data protection laws, we may disclose certain personal information to such bodies or agencies. In the event of a legal claim, we may also need to disclose certain personal information to the court;
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 UK where our third party service providers have operations, including the EEA and the United States. Where this is required by law, any international transfers of your personal information will be made pursuant to appropriate safeguards, such as the approved Standard Contractual 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 (https://www.923jobs.com/privacy).
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: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/;
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: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-object/;
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 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 apply to client personal data which we process on the basis that it is required for the performance of our contract with you;
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, which can be contacted at: https://ico.org.uk/concerns/.
Further information about these rights generally is available at: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
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 Louise Arnold on 07967 205099 or louise@923jobs.com.
Updates to the 9-2-3 privacy policy
This privacy policy may be changed by 9-2-3 at any time. If from time to time we make any changes to this privacy notice which will affect our processing of your personal data, we will notify you by email.
9-2-3 Jobs Limited
07967 205099/louise@923jobs.com
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.