Privacy Policy X4 Group takes data privacy seriously. This privacy notice applies to X4 Group entities, across our global operations and we are committed to safeguarding the privacy and security of personal data we may collect from candidates and/or clients to whom we provide our services. This privacy notice aims to help you understand our personal data collection, usage and disclosure practices by explaining: Who we are What information we collect How we obtain the personal data about you How we use your personal data Your rights Who we share your personal data with Which countries we transfer your personal data to How long we keep your personal data Safeguarding measures Consequences of not providing your data Complaints Cookies Contact Updating this notice Who we are X4 Group (‘we’ or ‘us’ or ‘our’) is a global recruitment company, the members of which are X4 Group Ltd, X4 Group (New Zealand) Ltd, X4 Tech Staffing Inc. and X4 Staffing Deutschland GmbH. We gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data. X4 Group Ltd and X4 Group (New Zealand) Ltd are registered at Quadrant House, 4 Thomas More Square, London, E1W 1YW and are registered in England and Wales under company number 06711498 (UK) and 10965825 (NZ). Both entities are registered on the Information Commissioner’s Office Register; registration number 00044493711 (UK) and (Number (NZ). X4 Tech Staffing Inc. is registered in New York and operate at 10 Grand St Suite 1200, Brooklyn, NY 11249. X4 Staffing Deutschland GmbH is registered at Zimmerstrasse 23, UHY Deutschland AG, D-10969 Berlin, and is registered under District Court Charlottenburg (Berlin) HRB 223116 B. X4 Group act as Data Controller when processing your data. We may share information between our entities in the UK, the EEA and outside of the EEA if required by law, if consent is given or in order to pursue the data subject’s and our combined legitimate interest. Our designated Data Protection Officer/Appointed Persons are Niall Tierney and Sam Bysouth, who can be contacted at Brettenham House, Lancaster Place, London, WC2E 7EN or gdpr@x4group.co.uk. What information we collect X4 Group processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way other than as specified in this notice. The personal data that we collect from may include: – Name Date of Birth Home Address Personal Email Business Email Home Telephone Number Mobile Telephone Number National Insurance Number Passport Number Driver’s License Number Special Category Data (i.e. health/medical information, details about religion, sexuality etc) Employment History Special Categories Data Owing to the services that we offer, X4 Group sometimes needs to process sensitive personal information (known as special category data) about you, to comply with certain contractual agreements on behalf of our clients, or when it is essential to check as part of our duty of care responsibilities (i.e DBS check for working with vulnerable people). Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so. Where we rely on your consent for processing special category data, we will obtain your explicit consent through a signature or written consent. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so. If you consent to us collecting and using your sensitive personal information you can do so via email to gdpr@x4group.co.uk or by completing forms sent to you at the relevant time. How we obtain the personal data about you: – LinkedIn, Hunter, Sourcebreaker, Online applications, searching via partner websites, other social media sites, recommendations and referrals, CVs, application forms, company website etc. How We Use Your Personal Data (Legal Basis for Processing): – X4 Group takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law or to pursue a legitimate interest. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have provided you with promotional offers and marketing, you are free to unsubscribe to marketing at any time. The purposes and reasons for processing your personal data are detailed below: Contacting you regarding work opportunities Sending to clients in the interest of generating work opportunities Arranging interviews Assessing suitability for vacancies Emailing potential vacancies Contacting for updates to your personal details or career history Updating on changes to terms and conditions Any other activity reasonably associated with trying to find work opportunities Legitimate Interests X4 Group occasionally process your personal information under the legitimate interests legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate. We use the legitimate interests legal basis for processing any personal data needed in the interests of recruitment and staffing; primarily your name, phone number(s), email address, address and employment history, and have identified that our interests are to inform you of new vacancies and/or opportunities potentially suitable for you or to inquire further about details that could affect your employability. X4 Group will occasionally send you information on vacancies or requests to update your CV by email or SMS that have been identified as being beneficial to our customers and in their and our interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to unsubscribe at any time. If you would prefer not to receive above-mentioned marketing and offers, please unsubscribe by emailing gdpr@x4group.co.uk. Automated Decision Making Currently we do not carry out solely automated decision making. Automated individual decision-making is a decision made by automated means without any human involvement, this does not necessarily have to involve profiling, although it often will do. Profiling is a process of automated decision making which consists of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, personal preferences, interests, reliability, behaviour, location or movements. Your Rights You have the right to access any personal information that X4 Group Ltd processes about you, including: – What personal data we hold about you The purposes of the processing The categories of personal data concerned The recipients to whom the personal data has or will be disclosed How long we intend to store your personal data If we did not collect the data directly from you, information about the source If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified. You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use. If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. Who we share your personal data with X4 Group uses third parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures. Below is a list of the processors acting on our behalf: Anfold Software Ltd We use Anfold Software Ltd to provide specialist timesheet software on our behalf, which we refer to as our Timesheet Portal. The only information we provide them with is your name, address and ltd company details in order to meet business and legal requirements. For more information about Anfold Software Ltd, please read their privacy notice at https://www.timesheetportal.com/PrivacyPolicy.aspx itQED Ltd We use itQED Ltd to provide specialist outsourced IT support services on our behalf. Given the holistic nature of the support services they offer, any data that we process about you is also in turn processed by itQED Ltd, in order to meet business and legal requirements. For more information about itQED Ltd, please read their privacy notice at http://www.it-qed.co.uk/privacy-policy/ Microdec plc We use Microdec plc to provide specialist CRM software in order for us to manage our candidate and client relationships. They hold any applicable data relevant to your work-seeking activities, in order to meet business and legal requirements. For more information about Microdec plc, please read their privacy notice at http://www.microdec.com/legal-page/data-protection-policies Strategies Online Ltd We use Strategies Online Ltd to build, host and manage our website. The only information we provide them with would be the information provided by you should you apply through the application or registration forms on our website. For more information about Strategies Online Ltd, please read their privacy notice at https://www.strategies.co.uk/privacy/ Synergy Office (UK) Ltd We use Synergy Office (UK) Ltd to provide and host our telecommunications platform. In doing so, they may have access to information relating to you in the form of voice conversations held with our staff. For more information about Synergy Office (UK) Ltd, please read their privacy notice at http://www.synergygrp.co.uk/privacy-policy/ Which countries we transfer your personal data to Disclosure of your information inside and outside of the UK and EEA The data that we collect from you is stored in the United Kingdom. It may be transferred to, and/or stored at, a destination outside the UK or European Economic Area (”EEA”) for the purpose of our business. It may be processed by staff operating inside and outside the UK or EEA. This includes staff engaged in, among other things, our business and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice. Transfer Limitation Within the UK Restricted transfers from the UK to other countries, including the EEA, are subject to transfer rules under the UK regime. The UK “adequacy regulations” assess adequate protection for individuals’ rights and freedoms for their personal data, this includes the EEA and all countries, territories and international organisations covered by European Commission “adequacy decisions”. If we share information with another entity outside of the UK or EEA that does not meet the UKs adequacy regulations, we will ensure data transfer to these areas are subject to the appropriate safeguards set out in the UK GDPR. How Long We Keep Your Data X4 Group Ltd only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required in order to comply with certain aspects of UK legislation to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. Safeguarding Measures X4 Group Ltd takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: securely managed local firewalls, encrypted servers and back-ups securely restricted access permissions 13-character password policy group policies for anti-virus restricted downloads and auto-timeouts on physical machines multiple policies to control physical data, including auto-delete of local downloads, a data retention policy for physical data and a comprehensive confidential waste policy Consequences of Not Providing Your Data You are not obligated to provide your personal information to X4 Group, however as this information is required for us to provide you with our services and offer a legitimate business solution we will not be able to offer some/all our services without it. Lodging A Complaint If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office. You can contact them in the following ways: Phone: 0303 123 1113 Email: casework@ico.org.uk Post: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Contact If you have any questions about this policy please contact us by: Email: gdpr@x4group.co.uk; Phone: (+44) 0207-812-7700; or Post: X4 Group, Brettenham House 2-19 Lancaster Place London WC2E 7EN Updating this notice We review and update our policy on data protection and this notice on an annual basis in order to make sure it reflects our current data processing activities. We also issue updates with new services or changes in our processing. 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