24 Seven Privacy Policy Introduction Welcome to The 24 Seven Group’s privacy policy. The 24 Seven Group respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy. This policy has been designed with reference to the following legislation: •EU-US Privacy Shield (for specific sections on the Privacy Shield please see the following sections: “Privacy Shield”; “Important Information and Who we Are”; “Your Legal Rights”; “The Data We Collect About You”; “Disclosure of Your Personal Data”; and “Glossary”); •EU General Data Protection Regulation (“GDPR”); and •UK Data Protection Act 2018 We have also divided this privacy notice for various categories of third parties. Internal members of staff should refer to our separate privacy policy. Please click on the relevant link below to access the applicable privacy policy. •Website Users •Candidates (including potential candidates) •Clients •Suppliers Privacy Shield We comply with the EU-U.S. Privacy Shield Framework (and the Swiss-U.S. Privacy Shield Frameworks) (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (and the United Kingdom, as applicable) to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. In compliance with the Privacy Shield Principles, we commit to resolving complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact the Data Privacy Manager, as set out below. We have has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU. We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with us and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration). In addition to the other purposes set out in this Privacy Notice, as required by the Privacy Shied, we must disclose personal data to comply with lawful requests from public authorities, including to meet national security and law enforcement requirements. We are liable for onward transfers to third-party service providers or agents. General Provisions For each type of privacy notice set out above, the below will apply to all types of data subject. 1.Important information and who we are Purpose of this privacy policy This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or submit your information as a candidate, client or supplier. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. Controller The 24 Seven Group is made up of different legal entities as follows: •24 Seven Topco, LLC; •24 Seven, LLC; and •24 Seven UK Limited •24 Seven Talent Source ULC •Sage Consulting Associates, LLC This privacy policy is issued on behalf of the 24 Seven Group so when we mention "Company", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the 24 Seven Group responsible for processing your data. We will let you know which entity will be the controller for your data when you submit an enquiry or request a service with us. 24 Seven Topco, LLC is the controller and responsible for this website. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. Contact details If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways: Full name of legal entity: 24 Seven UK Limited Email address: DPM@24seveninc.com Postal address: 2 Stephen Street Fitzrovia London W1T 1AN Data subjects based in the UK have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the privacy policy and your duty to inform us of changes We keep our privacy policy under regular review. We reserve the right to amend this Policy from time to time consistent with the Privacy Shield's requirements and other applicable legislation (including the GDPR). This version was last updated on1 May 2019 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Third-party links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 2.Your Legal Rights You have the right to: Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms (although we will always remove your details from any marketing database if you ask us to do so). Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: •If you want us to establish the data's accuracy. •Where our use of the data is unlawful but you do not want us to erase it. •Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. •You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please see section 3 below for details of the lawful bases (other than consent) for which we process your personal data. If you wish to exercise any of the rights set out above, please contact us. No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated, but we may have the legal right to extend the time limit for responding. 3.Automated Decision Making You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. Save for website users (please see below), we do not envisage that any decisions will be taken about you using automated means. 4.Glossary LAWFUL BASIS We are obliged to have a lawful basis for processing your personal data. Other than consent, the most commonly used lawful bases for processing are the following: “Legitimate Interest”means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. “Performance of Contract”means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. “Comply with a legal obligation”means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. THIRD PARTIES Internal Third Parties These are defined as other companies in the 24 Seven Group acting as joint controllers or processors and who are based in the UK, the US and Canada. External Third Parties Examples of External Third Parties are: •Service providers acting as processors based in the U.S.A., U.K. and Canada who provide IT and system administration services. •Professional advisers acting as processors or joint controllers or controllers in their own right including lawyers, bankers, auditors and insurers based in the U.S.A., U.K. and Canada]who provide consultancy, banking, legal, insurance and accounting services. •HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers or controllers in their own right based in the United Kingdom. WEBSITE USERS 1. THE DATA WE COLLECT ABOUT YOU 2. HOW IS YOUR PERSONAL DATA COLLECTED? 3. HOW WE USE YOUR PERSONAL DATA 4. DISCLOSURES OF YOUR PERSONAL DATA 5. INTERNATIONAL TRANSFERS 6. DATA SECURITY 7. DATA RETENTION 1.The data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: •Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. •Contact Data includes address, email address and telephone numbers. •Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. •Profile Data includes your username and password, preferences, feedback and survey responses. •Usage Data includes information about how you use our website, products and services. •Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any Special Categories of Personal Data about you via our website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. 2.How is your personal data collected? We use different methods to collect data from and about you including through: •Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: •apply for our services; •create an account on our website; •submit your CV or qualification details (for further information please see our Candidate Privacy Policy); •subscribe to our service or publications; •request marketing to be sent to you; •enter a competition, promotion or survey; or •give us feedback or contact us. •Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details. •Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below: •Technical Data from the following parties: •analytics providers such as Google and Hubspot based outside the EU; and •Contact information found on client and candidate LinkedIn profiles based either outside or inside the EU. •Identity and Contact Data from publicly available sources such as Companies House, business websites and the Electoral Register based inside the EU. 3.How we use your personal data We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: •Where we need to perform the contract we are about to enter into or have entered into with you. •Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. •Where we need to comply with a legal obligation. Click here to find out more about the types of lawful basis that we will rely on to process your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Purposes for which we will use your personal data We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so (these are set out in brackets). Our legitimate interests include to keep our records updated and to study how clients and candidates use our services, develop and grow our business and inform our marketing strategy and provision of administration and IT services, network security. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below: •To register you as a new client or candidate (performance of a contract with you). •To manage our relationship with you which will include notifying you about changes to our terms or privacy policy and asking you to leave a review or leave a survey (performance of a contract with you, necessary to comply with a legal obligation and/or necessary for our legitimate interests). •To enable you to partake in a prize draw, competition or complete a survey (performance of a contract with you and/or necessary for our legitimate interests). •To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (necessary for our legitimate interests and/or necessary to comply with a legal obligation). •To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (necessary for our legitimate interests). •To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (necessary for our legitimate interests). •To make suggestions and recommendations to you about services that may be of interest to you (necessary for our legitimate interests). Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used services from us and you have not opted out of receiving that marketing. You will always be given the opportunity each time you receive marketing communications from us to unsubscribe from future communications of that nature. Third-party marketing We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. Opting out You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase. Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy. Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 4.Disclosures of your personal data We may share your personal data with the parties set out below for the purposes set out in “Purposes for which we will use your personal data” above. •Internal Third Parties as set out in the Glossary. •External Third Parties as set out in the Glossary. •Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 5.International transfers We may share your personal data within the 24 Seven Group. This will involve transferring your data outside the UK and the European Economic Area (EEA). In particular, we will store your details in our secure data storage centre located in the USA. Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: •Where applicable, we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. •Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For more information, please visit the Privacy Shield sections of this notice and https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and the EEA. 6.Data security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 7.Data retention How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. For website users, we will generally keep the types of personal data set out above for two years from your last visit to our website. In some circumstances you can ask us to delete your data: see your legal rights for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. CANDIDATES (INCLUDING POTENTIAL CANDIDATES) This section covers the following four categories of candidates and potential candidates: •Potential candidates whose details remain on third party sites such as Linked-In and job boards •Potential candidates who are put forward for roles •Freelance contractors who carry out temporary placements •Candidates who are placed into permanent placements 1. THE DATA WE COLLECT ABOUT YOU 2. HOW IS YOUR PERSONAL DATA COLLECTED? 3. HOW WE USE YOUR PERSONAL DATA 4. DISCLOSURES OF YOUR PERSONAL DATA 5. INTERNATIONAL TRANSFERS 6. DATA SECURITY 7. DATA RETENTION 1.The data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). For those potential candidates whose details remain on third party sites such as Linked-In and job boards, the processing activities are minimal because their details are never put on to our systems. We do not retain their personal data unless or until we consider that they may be suitable for placing with one or more of our clients. The details set out below relate to the other three categories of candidates and potential candidates outlined above. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: •The information you have provided to us in your curriculum vitae and enquiry forms. •The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, salary details and qualifications. •Any information you give us on the types of roles and organisations you are interested in. •Financial information, such as your bank account details (bank name, address, account number and sort-code) so we can pay you for assignments you work on with clients. •Your national insurance number and tax code. •Test results for any application assessments conducted by our clients. We may also collect, store and use the following types of more sensitive personal information: •Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions. •Information about your health, including any medical condition, health and sickness records. •Information about criminal convictions and offences. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with recruitment services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. 2.How is your personal data collected? We use different methods to collect data from and about you including through: •You, the candidate. •Disclosure and Barring Service in respect of criminal convictions (where applicable due to assignments you are asked to work on). •Data from third parties in a publicly accessible source such as your LinkedIn details and job boards and information disclosed within. 3.How we use your personal data We will use the personal information we collect about you to: •Assess your skills, qualifications, and suitability for the assignment(s) applied for. •Carry out background and reference checks, where applicable and required by our client. •Communicate with you about the recruitment process. •Keep records related to our hiring processes and services with you. It is in our legitimate interests to decide whether to assign you to our assignments or put you forward for permanent positions with our clients since it would be beneficial to our business to appoint someone to that assignment/role with our clients. We also need to process your personal information to decide whether to enter into a contract with you. Having received your CV and the results from any tests or interviews with us or our client, we will then process that information for the purpose of considering your suitability for an assignment. If you are offered an assignment, we will then carry out any further steps necessary, such as take up references, carry out a criminal record check or any other background checks required by our client for the assignment. If you are unsuccessful in securing a particular assignment or role (or decide not to take it up), we will retain your personal information for consideration for other assignments or roles unless you tell us otherwise. 4.Disclosures of your personal data We may share your personal data with the parties set out below for the purposes set out at “How we use your data” above. •Internal Third Parties as set out in the Glossary. •External Third Parties as set out in the Glossary. •Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 5.International transfers We share your personal data within the 24 Seven Group. This will involve transferring your data outside the UK and the European Economic Area (EEA). In particular, we will store your details in our secure data storage centre located in the USA. Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: •Where applicable, we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. •Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For more information, please visit the Privacy Shield sections of this notice and https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and the EEA. 6.Data security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 7.Data retention How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We will generally keep the personal information of each category of candidates/potential candidates as follows, unless there is a specific legal requirement that requires us to retain any information for longer: •Potential candidates whose details remain on third party sites such as Linked-In and job boards – no personal information retained; •Potential candidates who are put forward for roles – 12 months from the date of the last recruitment activity, such as interview with a client; •Freelance contractors who carry out temporary placements – 6 years from the end of the contractual relationship; •Candidates who are placed into permanent placements – 12 months from the date of the placement. In some circumstances you can ask us to delete your data: see your legal rights for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. CLIENTS 1. THE DATA WE COLLECT ABOUT YOU 2. HOW IS YOUR PERSONAL DATA COLLECTED? 3. HOW WE USE YOUR PERSONAL DATA 4. DISCLOSURES OF YOUR PERSONAL DATA 5. INTERNATIONAL TRANSFERS 6. DATA SECURITY 7. DATA RETENTION 1.The data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: •The information you have provided to us in enquiry forms. •The information you have provided in communications with us, including name, title, employer, job title, address, telephone number, email address, date of birth, gender. We do not anticipate that we will collect any types of special category data from you (such as race, religion, trade union membership or criminal convictions). If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with recruitment services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. 2.How is your personal data collected? We use different methods to collect data from and about you including through: •You, the client. •Data from third parties in a publicly accessible source such as your LinkedIn details, business website and information disclosed within. 3.How we use your personal data We will use the personal information we collect about you to: •Carry out our recruitment services with you. •Fulfil requests to place candidates within your organisation. •Obtain feedback on services we have provided to you in the past. •Communicate with you about our services process. •Forward you details of candidates we believe may be of interest to you. •Provide you with our latest marketing. •Record your preferences in receiving marketing from us and our third parties and your communication preferences. It is in our legitimate interests to decide what recruitment services we are to provide to you since it would be beneficial to our business to appoint candidates within your organisation to fulfil your requests. We also need to process your personal information to decide whether to enter into a contract with you. It is also in our legitimate interests to provide you with marketing updates, both on the services that we provide and candidates who may be of interest to your sector. You have the right to withdraw consent to marketing at any time by contacting us. 4.Disclosures of your personal data We may share your personal data with the parties set out below for the purposes set out above at “How we use your personal data”. •Internal Third Parties as set out in the Glossary. •External Third Parties as set out in the Glossary. •Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 5.International transfers We share your personal data within the 24 Seven Group. This will involve transferring your data outside the UK and the European Economic Area (EEA). In particular, we will store your details in our secure data storage centre located in the USA. Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: •Where applicable, we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. •Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For more information, please visit the Privacy Shield sections of this notice and https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and the EEA. 6.Data security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 7.Data retention How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. For clients, we will generally keep the types of personal data set out above for six years from the end of your last engagement with us (or if we do not provide any services from you, six years from the date of your initial enquiry). In some circumstances you can ask us to delete your data: see your legal rights for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. SUPPLIERS 1. THE DATA WE COLLECT ABOUT YOU 2. HOW IS YOUR PERSONAL DATA COLLECTED? 3. HOW WE USE YOUR PERSONAL DATA 4. DISCLOSURES OF YOUR PERSONAL DATA 5. INTERNATIONAL TRANSFERS 6. DATA SECURITY 7. DATA RETENTION 1.The data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: •The information you have provided to us in enquiry forms. •The information you have provided in communications with us, including name, title, employer, job title, address, telephone number, email address, date of birth, gender. We do not anticipate that we will collect any types of special category data from you (such as race, religion, trade union membership or criminal convictions). If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have with you to provide services to us or are trying to enter into with you. In this case, we may have to cancel a service you provide to us but we will notify you if this is the case at the time. 2.How is your personal data collected? We use different methods to collect data from and about you including through: •You, the supplier. •Data from third parties in a publicly accessible source such as your LinkedIn details, business website profile and information disclosed within. 3.How we use your personal data We will use the personal information we collect about you to: •Contract with you to provide services. •Obtain and provide feedback on services you have provided to us in the past. •Communicate with you about the services. It is in our legitimate interests to decide what services you provide to us. We also need to process your personal information to decide whether to enter into a contract with you. Where applicable, you have the right to withdraw consent to marketing at any time by contacting us. 4.Disclosures of your personal data We may share your personal data with the parties set out below for the purposes set out in the table “How we use your personal data” above. •Internal Third Parties as set out in the Glossary. •External Third Parties as set out in the Glossary. •Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 5.International transfers We share your personal data within the 24 Seven Group. This will involve transferring your data outside the UK and the European Economic Area (EEA). In particular, we will store your details in our secure data storage centre located in the USA. Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: •Where applicable, we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. •Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For more information, please visit the Privacy Shield sections of this notice and https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and the EEA. 6.Data security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 7.Data retention How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. For suppliers, we will generally keep the types of personal data set out above for six years from the end you last performed services for us. In some circumstances you can ask us to delete your data: see your legal rights for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 24 Seven FIND WORK FIND TALENT FREELANCE FULL-TIME EXECUTIVE SEARCH BROWSE JOBS BLOG RESOURCES UPSKILL WORKSHOP DEI POLICY SUPPORT REFERRAL BONUS CONTACT US SIGN UP CONNECT WITH US 24 SEVEN FAMILY OF COMPANIES Privacy Policy Terms of Use 24 Seven Talent 2021 © All rights reserved. Website by