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Harris Global company insight for the purpose of obtaining and processing data

Who we are and what we do

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

  • Prospective and placed candidates for permanent or temporary roles;
  • Prospective and live client contacts;
  • Supplier contacts to support our services;
  • Employees, consultants, temporary workers;

We collect information about you to carry out our core business and ancillary activities.

Any referenced to:

‘we or ‘our’ means Harris Global Limited who’s registered offices are Sunley House 4th Floor Bedford Road Croydon CR0 2AP, Company number 7366327.

‘Third party suppliers’ of data means, Job boards, LinkedIn, CV Search job boards, online adverts where candidates have given permission and uploaded their data themselves for the purpose of finding future work.

‘Third party processors’ of data mean, those who we work with to support the functionality of our organisation such as Financing, database storage, employee payroll and pensions, contractor payments and invoicing.  Agreements and their purposes and processes have been reviewed by the board of directors within Harris Global to ensure that the data they process on our behalf is handled correctly and in line with The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.

Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection legislation in force from time to time the data controller is Harris Global Limited of Sunley House, 4th Floor, 4 Bedford Park Road, Croydon, CR0 2AP.  Company number 7366327.

Our nominated representative for GDPR is Kirsty Hotston, kirstyhotston@harris-global.com

 

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.

To provide you with information about other goods and services we offer that are similar to those that you have already liaised with you about, been provided with or enquired about.

The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement.  However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.

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

We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

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

We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.  Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).

  

Our Legitimate Business Interests

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

As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts.  The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.

In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.

To deliver our ancillary services we need to make contract and build relationships by liaising with clients and candidates in order to support their career aspirations and resourcing needs

 

Why we process and collect the data we do:

Information you provide to us is stored on our secure servers and cloud databases. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

Information you give to us or we collect about you.

This is information about you that you give us by submitting your CV and details to us on our site www.harris-global.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, or other social media functions on our site.

The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

Data is also regularly obtained through individual submissions from candidates and clients.  This engagement is often from direct approach or submission of personal data that have submitted directly or a via a third- party supplier of Harris.  All of this data obtained has been uploaded directly by candidates in order to be considered for work opportunities or resourcing needs. Data is then stored on our company database and used for current and future legitimate business reasons.  This data in stored for set periods of times as set-out within our data mapping.  Please also refer to our Data Retention Notice.

 

Information we obtain from other sources.

This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case we will inform you, by sending you a link to access this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data. Your data will never be shared with a client or third party unless further consent to do so has been obtained by you.

We are working closely with third parties including, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services. These may include DBS checks which you have provided us with for the purpose of processing your application for a job.

 

Disclosure of your information inside and outside of the EEA

We will share your personal information with:

Selected third parties including:

  • clients for the purpose of introducing candidates to them;
  • candidates for the purpose of arranging interviews and engagements;
  • clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
  • subcontractors including email marketing specialists, payment and other financial service providers
  • engine providers that assist us in the improvement and optimisation of our site;
  • credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

 

We will disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Harris Global Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply of services and other agreements; or to protect the rights, property, or safety of Harris Global, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

The lawful basis for the third party processing will include:

  • Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
  • satisfaction of their contractual obligations to us as our data processor;
  • for the purpose of a contract in place or in contemplation;
  • to fulfil their legal obligations.

 

Your rights  

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data  for marketing purposes.

You can exercise your right to accept or prevent such processing by expressing when checking certain boxes through our website when we collect your data. You can also exercise the right at any time by contacting our GDPR Coordinator kirstyhotston@harris-global.com

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

The GDPR provides you with the following rights.

To:

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party in certain formats, if practicable.
  • Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

 

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.  Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining or, if we have had no contact with you within a 4 year period your data will be removed from our database systems.  It is important that you keep us up to date with all current data.

We do the following to try to ensure our data is accurate:

  • Prior to making an introduction we check that we have accurate information about you
  • We keep in touch with you, so you can let us know of changes to your personal data
  • We always ask that you contact us should your details and circumstances change, and you wish us to amend the data we hold on you.
  • For Contractors that have worked through Harris on temporary assignments our ETZ contractor timesheet portal enables you to manage your data and to review whether the details we hold about you are accurate

We review and monitor the data we hold and the different types of data that we have on our systems so that it is reviewed, updated and only kept for time periods necessary and stated.  The criteria we use to determine whether we should retain your personal data includes:

  • the nature of the personal data;
  • its perceived accuracy;
  • our legal obligations;
  • whether an interview or placement has been arranged; and
  • our recruitment expertise and knowledge of the industry by country, sector and job role.

We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.

For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

 

How we will respond to a request of erasure and what this means at Harris:

How will the data we hold be deleted when requested?

When candidates request their data be erased from the system, we will do so by replacing identifying fields with Pseudonymised data. Users within our business who have a higher level of admin access and with the proper entitlements can choose Erase Data. When a candidate is anonymized, the request is captured and stored in the system.  If a candidate record is linked to another entity, all linked data is also anonymized.

    • Examples: Converted contacts, placement data, and submission data.

This will also remove all email correspondents that you may have had with a consultant here at Harris.

All personal history is erased and anonymised within 30 days of the erasure request being received and acknowledged by our GDPR Coordinator.

If you wish for your data to be erased from our data systems, you will need candidates will need to email or our nominated GDPR contact  kirstyhotston@harris-global.com  cc charlottebutler@harris-global.com

You will receive an email to confirm when this email has been acknowledged and the process of Erasure is starting. You will also receive a call from a Director or senior member of our management team to ensure that you are happy for us to continue with removing all data that we hold on file.

If you are a contractor that has previously been placed by Harris Global and have submitted more in-depth information such as your bank account details, Harris Global Limited will only continue to hold the data that is needed under HMRC requests and for the periods of time that as an organisation we are made to do so under the UK legislation.

 

Subject access request – How will we respond?

Access to information  

The Data Protection Act 1998 and the GDPR give you the right to access information held about you.  We also encourage you to contact us to ensure your data is accurate and complete.

Your right of access can be exercised in accordance with the Act.  All SAR  should be emailed to kirstyhotston@harris-global.com cc charlottebutler@harris-global.com  This will be dealt with within 30 days.

 

Changes to our privacy notice  

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice

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UK Address

Harris global Ltd.
Harris global Ltd.
Sunley House 4th Floor
Bedford Park
Croydon
CR0 2AP

Tel: 020 3510 2999
Fax: 0208 712 6344

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