At Practicus Limited (Practicus), maintaining your privacy is important to us and we take precautions to safeguard your information. After all your relationship with us is built on trust and our goal is to preserve that trust. This policy applies where we are acting as a data controller with respect to your information; in other words, where we determine the purpose and means of the processing of that information. This policy sets out the basis on which your information is collected, stored and used by us.
This policy explains how we process personal data in our recruitment business providing interim and permanent recruitment services, search, consulting and assessment services, including how it affects our website: www.practicus.com
Practicus Limited is committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the privacy and data protection laws applicable wherever we operate, as well as Data Protection Act 2018, GDPR and PECR regulations.
1. Who we are and how to contact us
Practicus must process personal data (including special categories of data) so that it can provide these services to you. In doing so, the Company acts as a data controller.
Data Privacy Office
Remenham Church Lane
2. Information we collect
By “information” we mean all the personal data about you that we collect, use, share and store. Most of the information collected by us is information which you have provided to us directly, whether this is from you signing up online to receive information from us or by your providing candidate or client information to us to help us provide our services to you.
Information Practicus collects from you when you visit and/or request to receive information from our website (by way of a non-exhaustive list):
- personal contact information (e.g., first name, family name, position in the company, company name, company email address, business phone number, business address, city, postcode, and country); and
- how you access and use our website or other digital services (e.g., your IP address, your location, the device, and software being used, pages visited, content viewed, links and buttons clicked through).
Information that Practicus collects or generate about you includes (by way of a non-exhaustive list):
- Practicus services which you have engaged with and our interactions with you; and
- your visits to Practicus Limited website including information collected through cookies that store technical information about the services that you use and how you use them.
If you are looking to become a candidate or client of ours, or are already a candidate or client of ours, in addition to the above, we may also collect or generate additional information about you. This includes (by way of a non-exhaustive list):
- regulatory requirements, such as right to work in the UK.
- candidate information, including date of birth and/or age, city or country of birth, and nationality.
- employment status including whether you are employed.
- proof of identification information, which may include a copy of your driver’s license, passport, or other appropriate identification documentation (depending on what you provide to us); and
- any other relevant information provided by you to us in correspondence, whether by email, written letter, or telephone call.
There may be some instances where we receive information about you from a third party. This includes (by way of a non-exhaustive list):
- background checks including information from social media.
Our clients expect that we identify the best individuals to fill roles within their organisations. So, we need to research systems, online databases, and other information sources, and talk to many individuals. Besides our clients, these will include referees and third-party sources to help inform our decision-making process.
The legal bases we rely upon to process your data and to offer these services to you are:
- Legitimate interest
- Statutory obligation
- Contractual obligation
In addition to the categories of information and legal bases described above, Practicus will also process further anonymised information and data that is not processed by reference to a specific individual. Your information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports which may be shared within Practicus.
3. How and why we use your information
We use the personal data we collect from you to provide our services to you:
- Processing job applications.
- Searching for relevant candidates for confidential recruitment assignments where our client is not initially named.
- We conduct from time-to-time mapping or research exercises on behalf of our clients. You will not be contacted by any third party about this unless we first obtain your consent.
- For the performance of a contract.
- For equality monitoring purposes, to understand the diversity of our applicant pool, but only if admissible under the applicable law. (This information is anonymised and aggregated).
- Improving the services, we offer.
- For marketing purposes to send you information on our services, white papers, newsletters, events and so forth. Please note you may opt out from receipt of marketing materials at any time by writing to us.
We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so.
We use client data to perform our services to you and other legitimate business purposes such as marketing.
Third party Sources and Referees
We use sources and referee’s data to perform our services.
We may use this information to enable us to market our services to you as a potential client. We may invite you to become a candidate in respect of the provision of our services.
The type of personal data we collect and process
In all cases we collect and process personal data about you, including your name, address, telephone number and email address.
If you proceed with a job application, or should we consult you about a role, you may be required to submit additional personal data.
Based on your explicit consent, we will process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.
From time to time, we may ask you to provide information relating to protected characteristics, such as your race or marital status. We do this for equal opportunity monitoring purposes and from time to time online, but only if that is admissible under local law. This information is always anonymised and aggregated and will not be revealed to third parties without your specific consent.
We might also collect personal data from third-party databases and other public sources.
As well as basic contact information we will collect information about your role and other information provided to us by your organisation.
Third party Sources and Referees
As well as basic contact information we will collect information regarding your credentials as a source, details of your relationship / knowledge of a candidate and your opinions of that individual. We may obtain this information directly from you or publicly available information.
What we do
Besides filling particular leadership vacancies, we process personal data when we conduct market intelligence exercises to map out business sectors or functions to help clients assess and review the available talent.
We will seek your consent to process personal data in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, genetic and / or biometric data. We encourage you not to provide us with sensitive personal data, unless it is specifically requested, and we have your specific consent.
Practicus is committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities.
- Data we may collect about you falls under the umbrella of “diversity information”. This could be data relating to your ethnic background, gender, disability, age, sexual orientation, religion, or other similar beliefs, and/or social-economic background.
- In accordance with local laws and requirements, Practicus will use this data on an anonymised basis to monitor our compliance with our equal opportunities policy.
- Practicus may disclose this (suitably anonymised where relevant) data to our clients where this is a contractual requirement or when specifically requested by clients to enable them to comply with their own employment processes.
- Such data is referred to as ‘sensitive’ personal data and stricter data protection rules apply. Practicus requires your explicit consent before we can utilise/share such data. We will ask for your consent by offering you an opt-in. This means that you must explicitly and clearly state that you agree for Practicus to collect and utilise such data.
- Practicus may collect other sensitive personal data, such as health-related information, religious affiliation, or details of any criminal convictions (where appropriate and in accordance with local laws) and if it is required for a job vacancy that you are interested in applying for. Please note that Practicus will never carry out any such activity without your explicit consent.
- The Data Protection Act 2018 (DPA 2018) outlines the requirement for an Appropriate Policy Document (APD) to be in place when processing special category (SC) data under certain specified conditions, Practicus complies in full with this requirement.
- For any Equality, Diversity, and Inclusion Reporting, Practicus source our data from the public domains i.e., data that is publicly available. Upon collection, data is anonymised, and the original data is deleted from our systems within 90 days.
4. Your rights
You have the following rights under data protection laws within the UK. In most cases you can exercise them free of charge.
You have the right to:
- be informed about the processing of your information.
- have your information corrected if it is inaccurate and to have incomplete information completed.
- object to or restrict processing of your information. Please note that there may be circumstances where you object to or ask us to restrict our processing of your information, but we are legally entitled to refuse that request.
- withdraw your consent to processing of your information at any time. Please note, however, that we may still be entitled to process your information if we have another legitimate reason for doing so (e.g., we may need to retain information to comply with a legal obligation).
- have your information erased in certain circumstances. Please note that there may be circumstances where you ask us to erase your information, but we are legally entitled to retain it.
- request access to your information and to obtain information about how we process it.
- move, copy, or transfer your information.
- receive some information in a structured commonly used and machine-readable format and/or request that we transmit that data to a third party where technically feasible. Please note that this right only applies to information which you have provided directly to Practicus and may not always apply.
- lodge a complaint with the relevant data protection regulator if you think any of your rights have been infringed by us; and
- be informed how your information is used in relation to automated decision making which has a legal effect on or otherwise significantly affects you.
- where you have consented to Practicus processing special categories of your personal data you have the right to withdraw that consent at any time by contacting the DPO, Practicus Limited, Riverside Barns, Remenham Church Lane, Henley-on-Thames, Oxfordshire RG9 3DB.
Please note that if you withdraw your consent for the future processing of your information, we may be unable to send you some marketing communications or information regarding events sponsored by Practicus. Additionally note, when we send you marketing, you will always be provided with an option to unsubscribe or opt out of receiving further marketing from us.
Data Privacy Office
Remenham Church Lane
5. Storage, transfers, and retention
The information that we collect from you is stored in the UK.
Should we have to transfer your information to another country outside the UK and EU, we will ensure that it is protected and transferred in a manner consistent with legal requirements of those countries falling outside of the UK and EU.
In relation to information being transferred outside of the UK and EU, for example, this may be done in one of the following ways:
- the country that we send the information to might be approved by the European Commission as offering an adequate level of protection for information
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your information.
- the country that we send the information to may subscribe to an “international framework” intended to enable secure data sharing
- where the recipient is in the US, it might be a certified member of the EU-US Privacy Shield scheme or CCPA legislation
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work- seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
Where we hold them, we must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Where we have obtained your personal data as part of a recruitment process, we will retain it for a maximum period of 3 years unless we had meaningful contact with you during that period.
We will retain information as needed to fulfil the purposes for which it was collected. We will retain and use your information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements. We will not retain your information for longer than is reasonably necessary.
We have physical, administrative, procedural, and technical safeguards in place to protect your information from unauthorised access, use or disclosure. We also contractually require that our third-party service providers protect such information to the standard required in the UK. We regularly adapt these controls to respond to changing requirements and advances in technology.
As a condition of employment, Practicus employees are required to follow all applicable laws and regulations, including data protection laws. Access to sensitive information is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client information by a Practicus employee is prohibited and may result in disciplinary measures.
7. Making changes to this information
We will keep this information up to date and it will always be available at practicus.com or on request at any time.
Feedback – Your opinion matters to us, firstname.lastname@example.org.
We may record telephone calls for our mutual protection, to improve customer service and for regulatory record keeping purposes.