INTRODUCTION:

  • This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates, or you are visiting our website.
  • It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
  • This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers, and other people whom we may contact in order to find out more about our Candidates or who they indicate is an emergency contact. It also applies to the emergency contacts of our Staff.
  • For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the company responsible for your personal data (“Robertson Sumner” or “us”) can be found in appendix one.
  • It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.
  • If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.

PERSONAL DATA:

What kind of personal data do we collect?

CANDIDATE DATA:

  • In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you.
  • Depending on the relevant circumstances, we may collect some or all of the information listed below toenable us to offer you employment opportunities which are tailored to your circumstances and your interests. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:
    • Name
    • Age / Date of birth
    • Birth number
    • Sex / gender
    • Photograph
    • Marital status
    • Contact details
    • Education details
    • Employment history
    • Emergency contacts and details of any dependents
    • Referee details
    • Immigration status (whether you need a work permit)
    • Nationality / citizenship / place of birth
    • A copy of your driving licence and / or passport / identity card
    • Social security number (or equivalent in your country) and any other tax-related information
    • Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information
    • Details of any criminal convictions if this is required for a role that you are interested in applying for
    • Details about your current remuneration, pensions and benefits arrangements
    • Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website
    • Extra information that you choose to tell us
    • Extra information that your referees chooses to tell us about you
    • Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites
  • Please note that the above list of categories of personal data we may collect is not exhaustive

CLIENT DATA:

  • If you are a Robertson Sumner customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as: (i) finding Candidates who are the right fit for you or your organisation and / or (ii) notifying you of content published by Robertson Sumner which is likely to be relevant and useful to you.
  • The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your online engagement with Candidate profiles and other material published by Robertson Sumner, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us.

SUPPLIER DATA:

  • We don’t collect much data about Suppliers – we simply need to make sure that our relationship runs smoothly. We’ll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS:

  • All we need from referees is confirmation of what you already know about our Candidate or prospective member of Staff; so that they can secure that job they really want. Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we’ll obviously need the referee’s contact details (such as name, email address and telephone number). We’ll also need these details if our Candidate or a member of our Staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.

WEBSITE USERS:

  • We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website we will collect any information that you provide to us, for example your name and contact details.

A number of elements of the personal data we collect from you are required to enable us to fulfill our contractual duties to you or to others. Where appropriate, some are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly.

Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfill our contractual requirements or, in extreme cases, may not be able to continue with our relationship.

HOW DO WE COLLECT YOUR PERSONAL DATA?

CANDIDATE DATA:

We collect Candidate personal data in three primary ways:

  • Personal data that you, the Candidate, provide to us
  • Personal data that we receive from other sources
  • Personal data that we collect automatically

Personal data you give to us:

  • Robertson Sumner needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
  • There are numerous ways you can share your information with us. It all depends on what suits you. These may include:
    • Entering your details on the Robertson Sumner website or via an application form, as part of the registration process
    • Posting a hard copy CV to our office
    • Emailing your CV to a Robertson Sumner consultant or being interviewed by them
    • Applying for jobs through a job site in response to a Robertson Sumner advert

Personal data we receive from other sources:

  • We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
    • Your referees may disclose personal information about you
    • Our Clients may share personal information about you with us
    • We may obtain information about you from searching for potential Candidates from third party sources, such as LinkedIn and other job sites

Personal data we collect automatically;

  • To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.

CLIENT DATA:

We collect Client personal data in three ways;

  • Personal data that we receive directly from you
  • Personal data that we receive from other sources
  • Personal data that we collect automatically

Personal data that we receive directly from you;

  • We both share the same goal – to make sure that you have the best staff for your organisation. We will receive data directly from you in two ways:
    • Where you contact us proactively, usually by phone or email
    • Where we contact you, either by phone or email, or through our consultants’ business development activities more generally

Personal data we receive from other sources;

  • Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
    • From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us)
    • From delegate lists at relevant events
    • From other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them)

Personal data we collect via our website;

  • To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.

SUPPLIER DATA:

  • We collect your personal data during the course of our work with you.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS:

  • We collect your contact details only where a Candidate or a member of our Staff puts you down as their emergency contact or where a Candidate gives them to us in order for you to serve as a referee.

WEBSITE USERS:

  • When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website.
  • We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Candidate or Client of Robertson Sumner, we may use data from your use of our websites to enhance other aspects of our communications with or service to you.

HOW DO WE USE YOUR PERSONAL DATA?

Having obtained data about you, we then use it in a number of ways.

CANDIDATE DATA:

The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate, we will seek your consent to undertake some of these activities. We generally use Candidate data in four ways;

  • Recruitment Activities
  • Marketing Activities
  • Equal Opportunities Monitoring
  • To help us to establish, exercise or defend legal claims
  • In appropriate circumstances in the future, we may also use Candidate data for Profiling. Here are some more details about each:

Recruitment Activities;

  • Obviously, our main area of work is recruitment – connecting the right Candidates with the right jobs. We’ve listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any laws and requirements. Please note that this list is not exhaustive.
    • Collecting your data from you and other sources, such as LinkedIn
    • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment
    • Providing you with our recruitment services and to facilitate the recruitment process
    • Assessing data about you against vacancies which we think may be suitable for you
    • Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs
    • Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you
    • Allowing you to participate in specialist online training
    • Allowing you to participate in the interactive features of our services, when you choose to do so
    • Carrying out our obligations arising from any contracts entered into between us
    • Carrying out our obligations arising from any contracts entered into between Robertson Sumner and third parties in relation to your recruitment
    • Facilitating our payroll and invoicing processes
    • Carrying out customer satisfaction surveys
    • Verifying details you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws)
    • Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties
    • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you
  • We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object.

Marketing Activities;

  • We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:
    • Enable us to develop and market other products and services;
    • Market our full range of recruitment services to you
    • Send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you
    • Display promotional excerpts from your details on Robertson Sumner’s website(s) as a success story (only where we have obtained your express consent to do so)
    • Provide you with information about certain discounts and offers that you are eligible for by virtue of your relationship with Robertson Sumner
  • We need your consent for some aspects of these activities which are not covered by our legitimate interests(in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in (which we explain further below). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements.
  • Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.
  • If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time. Nobody’s perfect, even though we try to be. We want to let you know that even if you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn’t happen, but if it does, we’re sorry. We’d just ask that in those circumstances you opt out again.
  • All our marketing is based on what we think will serve our Clients and Candidates best, but we know we won’t always get it right for everyone. We may use your data to show you Robertson Sumner adverts and other content on other websites. Even where you have turned off cookies, it is still possible that you may see a Robertson Sumner advert, but in this case it won’t have been targeted at you personally, but rather at an anonymous audience.

Equal opportunities monitoring and other sensitive personal data;

  • We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of “diversity information”. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and /or social-economic background. Where appropriate and in accordance with local laws and requirements, we’ll use this information on an anonymised basis to monitor our compliance with our equal opportunities policy. We may also disclose this (suitably anonymised where relevant) data to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.
  • This information is what is called ‘sensitive’ personal information and slightly stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We’ll ask for your consent by offering you an opt-in. This means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.
  • We may collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your explicit consent.
  • Please note that in certain of the jurisdictions in which we operate, different rules apply to this sensitive data.
  • If you are not happy about this, you have the right to withdraw your consent at any time.

To help us to establish, exercise or defend legal claims;

  • In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

Profiling;

  • Although at present all our recruitment activities involve human-decision making during the process, we may in the future use fully automated technologies such as expert systems or machine learning to complete a Candidate selection process from end-to-end, where appropriate and in accordance with any local laws and requirements.
  • Where appropriate, we will seek your consent to carry out some or all of these activities. If you do not provide consent to profiling, your application will continue to be reviewed manually for opportunities you apply for, but your profile will not be automatically considered for alternative roles. This is likely to decrease the likelihood of us successfully finding you a new job.
  • You have the right to withdraw that consent at any time.

CLIENT DATA:

The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. We use Client information for;

  • Recruitment Activities
  • Marketing Activities
  • To help us to establish, exercise, or defend legal claims

Here are some more details about each:

Recruitment Activities;

  • Obviously, our main area of work is recruitment, through providing you with Candidates. We’ve listed below the various ways in which we use your data in order to facilitate this.
    • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities
    • Keeping records of our conversations and meetings, so that we can provide targeted services to you
    • Undertaking customer satisfaction surveys
    • Processing your data for the purpose of targeting appropriate marketing campaigns
  • We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.

Marketing Activities;

  • Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as our Global Skills Index to a corporate postal or email address.
  • If you are not happy about this, you have the right to opt out of receiving marketing materials.
  • Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding marketing activities.

To help us to establish, exercise or defend legal claims;

  • In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

SUPPLIER DATA:

The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.

  • We realise that you’re probably busy, and don’t want us to be contacting you about all sorts of things. To find the right balance, we will only use your information:
    • To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements
    • To offer services to you or to obtain support and services from you
    • To perform certain legal obligations
    • To help us to target appropriate marketing campaigns
    • In more unusual circumstances, to help us to establish, exercise or defend legal claims
  • We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
  • We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS:

We will only use the information that our Candidate gives us about you for the following purposes;

  • If our Candidates or Staff members put you down on our form as an emergency contact, we’ll contact you in the case of an accident or emergency affecting them
  • If you were put down by our Candidate or a prospective member of Staff as a referee, we will contact you in order to take up a reference. This is an important part of our Candidate quality assurance process, and could be the difference between the individual getting a job or not.
  • If you were put down by our Candidate or a prospective member of Staff as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients.
  • We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.

WEBSITE USERS:

  • We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs or Candidates to you that we think you’ll be interested in.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

CANDIDATE DATA:

  • We may share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we may also share your information with any of our group companies and associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.

CLIENT DATA:

  • We will share your data: (i) primarily to ensure that we provide you with a suitable pool of Candidates. Unless you specify otherwise, we may share your information with any of our associated third parties such as our service providers to help us meet these aims.

SUPPLIER DATA:

  • Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS:

  • Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.

WEBSITE USERS:

  • Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.

WHO MAY WE SHARE YOUR DATA WITH?

Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

  • Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies.
  • Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation).
  • Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems).
  • Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place.
  • Marketing technology platforms and suppliers.
  • In the case of Candidates: potential employers and other recruitment agencies /organisations to increase your chances of finding employment.
  • In the case of Candidates: third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job.
  • In the case of Candidates and our Candidates’ and prospective members of Staff’s referees: third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws.
  • If Robertson Sumner merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

  • We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
  • If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately.

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

  • We will delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
  • For those Candidates whose services are provided via a third party company or other entity, “meaningful contact” with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.
  • When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate we will consider there to be meaningful contact with you if you submit your updated CV onto our website or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.

To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

  • Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
  • The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Candidates, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
    • We can show that we have compelling legitimate grounds for processing which overrides your interests
    • We are processing your data for the establishment, exercise or defence of a legal claim
  • If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
  • Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
  • Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
  • Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
    • The data are no longer necessary for the purpose for which we originally collected and/or processed them
    • Where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing
    • The data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR)
    • It is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller
    • If we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing
  • We would only be entitled to refuse to comply with your request for one of the following reasons;
    • To exercise the right of freedom of expression and information
    • To comply with legal obligations or for the performance of a public interest task or exercise of official authority
    • For public health reasons in the public interest o For archival, research or statistical purposes
    • To exercise or defend a legal claim
  • When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
  • Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
  • The circumstances in which you are entitled to request that we restrict the processing of your personal data are;o Where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified. Where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data. Where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it. Where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims
  • If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
  • Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
  • Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Robertson Sumner account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfill a contract.
  • Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact can be found in ‘Appendix Two’.
  • If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
  • You may ask to unsubscribe from job alerts at any time. Details of how to contact can be found in ‘Appendix Two’.
  • It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

  • All data used by Robertson Sumner is located within the UK on either an internal, firewalled, server which is maintained to the highest security protocols practically possible or within a cloud environment. All cloud located sources used are located within the UK/EU and are selected with IT security and GDPR compliance as an integral requirement
  • In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred:
    • Between and within Robertson Sumner entities
    • To third parties (such as advisers or other Suppliers to the Robertson Sumner business)
    • To overseas Clients
    • To Clients within your country who may, in turn, transfer your data internationally
    • To a cloud-based storage provider
    • To other third parties
  • We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example;
    • By way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws
    • By signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions
    • Transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation
    • Where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours)
    • Where you have consented to the data transfer
  • To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

OUR LEGAL BASES FOR PROCESSING YOUR DATA:

LEGITIMATE INTERESTS:

  • Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
  • We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone’s a winner! However, you do have the right to object to us processing your personal data on this basis.
  • Please note that in certain of the jurisdictions in which we operate, a different legal basis for data processing might apply in certain cases.

CANDIDATE DATA:

  • We think it’s reasonable to expect that if you are looking for employment or have posted your professionalCV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies. Once it’s looking like you may get the job, your prospective employer may also want to double check any information you’ve given us (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other Candidates get the jobs you deserve.
  • We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.
  • We have to make sure our business runs smoothly, so that we can carry on providing services to Candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.
  • We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting! If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.

CLIENT DATA:

  • To ensure that we provide you with the best service possible, we store your personal data and / or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.

SUPPLIER DATA:

  • We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS:

  • If you have been put down by a Candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.
  • If a Candidate or Staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.

CONSENT:

  • In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
  • Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that;
    • You have to give us your consent freely, without us putting you under any type of pressure
    • You have to know what you are consenting to – so we’ll make sure we give you enough information
    • You should have control over which processing activities you consent to and which you don’t.
    • You need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion
  • We will keep records of the consents that you have given in this way.
  • We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We areallowed to market products or services to you which are related to the recruitment services we provide aslong as you do not actively opt-out from these communications.
  • As we have mentioned, you have the right to withdraw your consent to these activities.

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

  • Sometimes it may be necessary for us to process personal data and, where appropriate and in accordancewith local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
  • This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

COOKIES POLICY:

What’s a cookie?

  • A “cookie” is a piece of information that is stored on your computer’s hard drive and which records yournavigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
  • Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.

How do we use cookies?

  • We use cookies to do two things;
    • To track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need
    • To help us advertise jobs to you that we think you’ll be interested in. Hopefully this means less time for you trawling through endless pages and will get you into the employment you want more quickly
  • Cookies are either;
    • Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
    • Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
  • Cookies can also be categorised as follows:
    • Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
    • Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
    • Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
    • Personalisation cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs that are similar to jobs that you have previously browsed.

APPENDIX 1 – HOW TO CONTACT US:

  • Country in which you use Robertson Sumner’s’ services or supply Robertson Sumner with services: UK
  • Entity responsible for processing the personal data of Website Users: Robertson Sumner Limited

How you can get in touch with us:

  • To access, amend or take back the personal data that you have given to us;
  • If you suspect any misuse or loss of or unauthorised access to your personal information
  • To withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data)
  • With any comments or suggestions concerning this Privacy Policy

You can write to us at the following address:

How you can get in touch with us to update your marketing preferences;

  • You can write to us at the following address: Europa House, Packhorse Road, Gerrards Cross, Buckinghamshire, SL9 8BQ
  • Alternatively you can email us at: enquiries@robertson-sumner.com or by clicking the unsubscribe link in any marketing e-mail we send to you.

APPENDIX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY:

  • Country in which you use Robertson Sumner’s services or supply Robertson Sumner with services: UK
  • Details of your local supervisory authority: The Information Commissioner’s Office. You can contact them in the following ways:
    • Phone: 0303 123 1113
    • Email: casework@ico.org.uk
    • Live chat
    • Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

APPENDIX 3 – GLOSSARY:

  • Candidates – includes applicants for all roles advertised or promoted by Robertson Sumner, including permanent, part-time, temporary positions and freelance roles with Robertson Sumner’s Clients; as well as people who have supplied a speculative CV to Robertson Sumner not in relation to a specific job. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with Robertson Sumner, will be treated as candidates for the purposes of this Privacy Policy.
  • Clients – while it speaks for itself, this category covers our customers, clients, and others to whom Robertson Sumner provides services in the course of its business.
  • Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.
  • General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
  • Other people whom Robertson Sumner may contact – these may include Candidates’ and Robertson Sumner’s Staff emergency contacts and referees. We will only contact them in appropriate circumstances.
  • Staff – includes employees and interns engaged directly in the business of Robertson Sumner (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to Robertson Sumner (even though they are not classed as employees). To be clear, ‘Staff’ does not include individuals hired by Robertson Sumner for the purpose of being placed with Clients. These individuals are treated in the same way as Robertson Sumner’s Candidates and are covered by this Privacy Policy. Likewise, independent contractors and consultants performing services for Robertson Sumner fall within the definition of a ‘Supplier’ for the purposes of this Privacy Policy.
  • Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Robertson Sumner. In certain circumstances Robertson Sumner will sub-contract the services it provides to Clients to third party suppliers who perform services on Robertson Sumner’s behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as Candidates for data protection purposes. Please note that in this context, Robertson Sumner requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at Candidates) to their employees.
  • Website Users – any individual who accesses the Robertson Sumner website.

Force24 Cookies & Tracking

Our organisation utilises Force24’s marketing automation platform.

Force24 cookies are first party cookies and are enabled at the point of cookie acceptance on this website. The cookies are named below:

  • F24_autoID
  • F24_personID

They allow us to understand our audience engagement thus allowing better optimisation of marketing activity.

f24_autoId – This is a temporary identifier on a local machine or phone browser that helps us track anonymous information to be later married up with f24_personid. If this is left anonymous it will be deleted after 6 months . Non-essential, first party, 10 years, persistent.

f24_personId – This is an ID generated per individual contact in the Force24 system to be able to track behaviour and form submissions into the Force24 system from outside sources per user. This is used for personalisation and ability to segment decisions for further communications. Non-essential, first party, 10 years, persistent.

The information stored by Force24 cookies remains anonymous until:

  • Our website is visited via clicking from an email or SMS message, sent via the Force24 platform and cookies are accepted on the website.
  • A user of the website completes a form containing email address from either our website or our Force24 landing pages.

The Force24 cookies will remain on a device for 10 years unless they are deleted.

Other Tracking

We also use similar technologies including tracking pixels and link tracking to monitor your viewing activities

Device & browser type and open statistics

All emails have a tracking pixel ( a tiny invisible image ) with a query string in the URL. Within the URL we have user details to identify who opened an email for statistical purposes.

Link Tracking

All links within emails and SMS messages sent from the Force24 platform contain a unique tracking reference, this reference help us identify who clicked an email for statistical purposes.