Strategy Recruitment LLP Privacy Policy

At Strategy Recruitment Solutions LLP (Strategy RS) we are committed to protecting and respecting your privacy. This privacy policy sets out how Strategy RS uses, protects and processes any information that we collect from you or that you provide to us.

Strategy RS is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using our recruitment services, then you can be assured that it will only be used in accordance with this privacy statement.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

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.

Who we are and what we do?

We are a recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003. We collect the personal data of the following types of people to allow us to undertake our business:

For job seekers (candidates), we may collect the following information as part of our initial stages of recruiting:

  • Your name and contact details (i.e. address, home and mobile phone numbers, email address);
  • Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests;
  • Details of your referees.
  • Evidence of previous performance (sales figures, awards, targets)

For clients (companies and hiring managers), we may collect the following information as part of our recruiting process:

  • Your name and contact details (i.e. address, work and mobile phone numbers, email address);
  • Details of your employment history and interests;
  • References that we collect from you.

How we collect the information?

We may collect this information from you, your referees (details of whom you will have provided), your education provider, the relevant professional body, the Disclosure and Barring Service (DBS) and the Home Office. By telephone, email and website cookies.

Why we collect the information and how we use it?

We will typically collect and use this information for the following purposes:

  • For compliance with a legal obligation (e.g. our obligation to check that you are eligible to work in the United Kingdom);
  • For the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

Our Legitimate Business Interests

Our legitimate interests in collecting and retaining your personal data is described below:

  • As a recruitment business we introduce candidates to clients for permanent employment only.
  • In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
  • To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.

How long we keep your information?

  • We keep the personal information that we obtain about you for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful, and you become engaged by us or whether we have regular contact with you for recruitment purposes, the nature of the information concerned and the purposes for which it is processed.
  • We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information are subject to a duty of confidentiality.

Purposes of the processing and the legal basis for the processing

Strategy RS will collect, use, store and otherwise process your Personal Data for the purposes of Strategy RS’ recruitment or resourcing activities. Additionally, your personal data may be processed for other purposes you have consented to such as marketing information or other information we think will be of legitimate interest to you.

Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.

We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.

We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.  Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate), as well as processing your data for internal marketing communications. Your data will only ever be sent to our clients with your prior permission.

Should we want, need or rely on consent to lawfully process your data we will request your consent orally, by email, or by an online process for the specific activity that we require consent for and record your response on our system. Whenever necessary and subject to statutory record-keeping requirements, Strategy RS will delete and/or anonymise Personal Data that is no longer needed. If there has not been any recent activity between yourself and Strategy RS, we may delete your profile after a reasonable time in compliance with the GDPR legislation.

In further detail, Strategy RS will process your Personal Data for the following purposes:

Communicating with you, in context of recruitment activities, such as:

  • To obtain additional information where necessary;
  • To inform you of available vacancies;
  • To provide you with information relating to your application and to fulfil your requests.

Managing recruitment and resourcing activities, including activities related to organisational planning. During recruitment activities, we may use your information:

  • To set up and conduct interviews and assessments;
  • To evaluate, select and recruit applicants;
  • To conduct background and credit checks and assessments as required or permitted by applicable local law;
  • To contact third party references provided by you to evaluate your previous performances.
  • Or as otherwise necessary in context of recruitment activities.

Development of services:

We may use your Personal Data to develop and improve our recruitment processes, websites and other related services. Where feasible, we use aggregated anonymous information in context of the development activities.

Legal and regulatory compliance, including obtaining and releasing Personal Data as required by law, judicial organizations or practice in order to comply with legal obligations imposed on us.

Transfer of your Personal Data

Strategy RS will not sell, lease, rent or otherwise disclose your Personal Data unless you have given explicit consent. Strategy RS may share your Personal Data if you have given your informed consent for Strategy RS to do so.

We do not undertake automated decision making or profiling. We do however use our systems to search and identify personal data in accordance with the parameters set by a person. A person will always be involved in the decision-making process.

 Where information may be held

Information may be held at our offices, and third-party agencies, service providers, and agents.

How long we keep your information

We keep the personal information that we obtain about you for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful, and you become engaged by us or whether we have regular contact with you for recruitment purposes, the nature of the information concerned and the purposes for which it is processed.

We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • Fair processing of information and transparency over how we use your use personal information
  • Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
  • Require us to correct any mistakes in your information which we hold
  • Require the erasure of personal information concerning you in certain situations
  • Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • Object at any time to processing of personal information concerning you for direct marketing
  • Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • Object in certain other situations to our continued processing of your personal information
  • Otherwise restrict our processing of your personal information in certain circumstances

The GDPR provides you with the following rights

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party in certain formats, if practicable.

The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. For any of the above please write to Strategy Recruitment Solutions LLP, AV House, Amor Way, Letchworth, SG6 1GU or data@strategyrecruitment.co.uk. If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.