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Linea Resourcing Ltd
Data Protection Policy
17th May 2018

1. Introduction

  • This Policy describes how we collect, use and process your personal data, and how we comply with our legal obligations to you in accordance with the General Data Protection Regulation (GDPR).
  • Linea Resourcing Ltd is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
  • This Policy applies to candidates, clients, suppliers, referees and emergency contacts.
  • This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out herein must be followed at all times by Linea, its employees, agents, contractors, or other parties working on behalf of the company.
  • Please note that we may occasionally amend this Data Protection Policy and any amendments will be available via this webpage.

If you have any questions regarding this policy, please do not hesitate to contact us – 02920 775 910. Our Data Protection Representative is MD, Mike Gorshkov.

2. The Personal Data We Store

The data we collect is limited to what is necessary to ensure our relationship with you runs smoothly. The following personal data may be collected, held, and processed by us:

Candidate Data:

  • Name, address, telephone number and email address for identification and correspondence;
  • Social media links to provide further information from websites such as LinkedIn and other files or links to demonstrate examples of work;
  • Work history and education details in the form of a CV, or similar, to illustrate experience and qualifications;
  • Notice period and current/preferred salary information for offer stage; and
  • Proof of right to work in the UK (i.e. passport, birth certificate, work permit etc.), bank details, VAT registration and Limited/Umbrella company details only if engaged in a contract for services through Linea Resourcing Ltd.
  • Correspondence between parties and records of job applications and results in order to track the job search and improve the process.
  • Any additional information that you have chosen to provide us.

Client Data:

  • Name, address, telephone number and email address for identification and correspondence;
  • Details of vacancy specifications or requirements;
  • CV and interview feedback;
  • Any additional information that you have chosen to provide us.

Supplier Data:

  • Name, address, telephone number and email address for identification and correspondence;
  • Any additional information that you have chosen to provide us.

Referees and Emergency Contact Data:

  • Name, address, telephone number and/or email address for reference or emergency purposes.
  • Any additional information that you have chosen to provide us.

3. Collection of Personal Data

  • Candidate Data:  We collect personal data directly from you and/or from third parties (for example, recruitment websites, job boards, social media etc).
  • Client Data:  We collect your personal data directly from you and/or from third parties e.g. our Candidates and media sources.
  • Supplier Data:  We collect your personal data via media sources and throughout our work with you.
  • Referees and Emergency Contact Data:  We collect your contact details when a candidate or employee lists you either as their emergency contact or referee.

4. Use of Personal Data

  • Candidate Data:  The sole reasons for us using your personal data are to help you find employment and to improve our services. The more information we have about you, your skillset and your goals, the more we can tailor our service to suit your job search.
  • Client Data:  The main reason for using information about you, is to ensure that the recruitment process runs smoothly. This involves connecting you with candidates that we think will be the right fit for your organisation. The more information we have about a vacancy, the more we can tailor our service to your needs.
  • Supplier Data:  The main reasons for using your personal data are to ensure that the contract between us can be met, to obtain goods, support or services and to comply with legal requirements.
  • Referees and Emergency Contact Data:  We use referees’ personal data to verify candidate or employee details and qualifications. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of emergency contacts in the case of an accident or emergency affecting a candidate or employee.

Please note that communications to and from us, including emails, may be reviewed as part of internal or external investigations or litigation.

5. Sharing Personal Data

  • Candidate Data:  We will share your information with prospective employers to increase your chances of securing the job you are looking for. We may also share your information with our service providers if you are placed in a contract role but we will notify you before doing so.
  • Client Data:  We will share your data to ensure that we provide you with a suitable candidates.
  • Supplier Data:  Unless you specify otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.
  • Referees and Emergency Contacts:  We will not share your personal data with associated third parties such as our service providers and organisations to whom we provide services.

6. The Data Protection Principles

This Policy aims to ensure compliance with the GDPR, which sets out the following principles with which any party handling personal data must comply.  All personal data must be:

A.  Lawful, Fair, and Transparent Data Processing

The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.  The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

  • you have given consent to the processing to your personal data for one or more specific purposes;
  • processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which the controller is subject;
  • processing is necessary to protect your vital interests or of another natural person;
  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by your fundamental rights and freedoms which require protection of personal data, in particular where the data subject is a child.

Our legal basis for processing data is documented at the end of this Policy.

B.  Processed for Specified, Explicit and Legitimate Purposes

We collect and process personal data specifically for recruitment purposes and to improve our service. This may include personal data received directly from you (for example, your career ambitions) and data received from third parties (for example, recruitment websites, job boards, social media, referencing providers etc.)

C.  Adequate, Relevant and Limited Data Processing

We will only collect and process personal data for and to the extent necessary for the specific purposes, above.

D.  Accuracy of Data and Keeping Data Up to Date

We shall ensure that all personal data collected and processed is kept accurate and up-to-date.  The accuracy of data shall be checked when it is collected and at regular intervals thereafter.  Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

E.  Timely Processing

We will not keep personal data for any longer than is necessary, in relation to the purposes for which that data was originally collected and processed. If we have not had ongoing contact with you (or, where applicable, the company you are working for or with) for a period of five years, we will delete our personal data from our systems unless we believe, in good faith, that the law or other regulation require us to retain it (for example, because of our obligations to HMRC or in connection with any anticipated litigation).

When the data is no longer required, all reasonable steps will be taken to erase it without delay.

F.  Secure Processing

We shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage.

G.  Accountability

Our Data protection Representative is MD, Mike Gorshkov, telephone: 02920 775 910. We shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

  • Our name and contact details, our data protection representative, and any applicable third-party data controllers;
  • The purposes for which we process personal data;
  • Details (and categories) of any third parties that will receive personal data from us;
  • Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
  • Details of how long personal data will be retained by us; and
  • Detailed descriptions of all technical and organisational measures taken by us to ensure the security of personal data.

7. Privacy Impact Assessments

We will carry out Privacy Impact Assessments as appropriate.  Privacy Impact Assessments shall be overseen by our Data Protection Representative and shall address the following areas of importance:

  • The purpose(s) for which personal data is being processed and the processing operations to be carried out on that data;
  • Details of the legitimate interests being pursued;
  • An assessment of the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
  • An assessment of the risks posed to individuals; and
  • Details of the measures in place to minimise and handle risks including safeguards, data security, and other measures and mechanisms to ensure the protection of personal data, sufficient to demonstrate compliance with the GDPR.

8. Your rights

You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below.  We will require evidence of your identity before we are able to act on your request. The GDPR sets out the following rights:

A.  Keeping You Informed

We will ensure that the following information is provided when personal data is collected:

  • Our name and contact details of our Data Protection Representative, Mike Gorshkov;
  • The purpose(s) for which the personal data is being collected and will be processed and the legal basis justifying that collection and processing;
  • Where applicable, the legitimate interests upon which we are justifying collection and processing of the personal data;
  • Where the personal data is not obtained directly, the categories of personal data collected and processed;
  • Where the personal data is to be transferred to one or more third parties, details of those parties;
  • Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place;
  • Details of the length of time the personal data will be held by us (or, where there is no predetermined period, details of how that length of time will be determined);
  • Details of your rights under the GDPR;
  • Details of your right to complain to the Information Commissioner’s Office (the ‘supervisory authority’);
  • Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it;
  • Details of any automated decision-making that will take place using the personal data (including but not limited to profiling), including information on how decisions will be made, the significance of those decisions and any consequences.

The information set out above shall be provided at the following applicable time:

  1. Where the personal data is obtained directly, at the time of collection;
  2. Where the personal data is not obtained directly (i.e. from another party):
  • If the personal data is used to communicate, at the time of the first communication; or
  • If the personal data is to be disclosed to another party, before the personal data is disclosed; or
  • In any event, not more than one month after the time at which we obtain the personal data.

B.  Access to Your Data

You may make a subject access request (“SAR”) at any time to find out more about the personal data we hold about you.  We are normally required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases you shall be informed of the need for the extension).

All subject access requests received must be forwarded to Mike Gorshkov, our Data Protection Representative. Telephone: 02920 775 910 / Email: mike@linearesourcing.co.uk.

We do not charge a fee for the handling of normal SARs. We reserve the right to charge reasonable fees for additional copies of information that has already been supplied to you, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

C.  Rectification of Personal Data

If you let us know that personal data held by us is inaccurate or incomplete, the personal data in question shall be rectified, and you will be kept informed of that rectification, within one month of receipt (this can be extended by up to two months in the case of complex requests, and in such cases you will be informed of the need for the extension).

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.

D.  Erasure of Personal Data

You may request that we erase the personal data we hold about you in the following circumstances:

  • It is no longer necessary for us to hold that personal data with respect to the purpose for which it was originally collected or processed;
  • You object to us holding and processing your personal data (and there is no overriding legitimate interest to allow us to continue doing so);
  • The personal data has been processed unlawfully;
  • The personal data needs to be erased in order for us to comply with a particular legal obligation.

Unless we have reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and you will be informed of the erasure, within one month of receipt of your request (this can be extended by up to two months in the case of complex requests, and in such cases the you shall be informed of the need for the extension).

We will delete your data but will generally assume that you would prefer us to keep a note of your name on our list of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data is collected in unconnected circumstances. If you would prefer us not to do this, please let us know.

In the event that any personal data that is to be erased in response to a request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

E.  Restrict Processing

You may request that we stop processing your personal data.  If you make such a request, we shall retain only the amount of personal data pertaining to you that is necessary to ensure that no further processing of your personal data takes place.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

F.  Data Portability

Where you have given your consent to us to process their personal data in such a manner or the processing is otherwise required for the performance of a contract between us and you, you have the legal right under the GDPR to receive a copy of your personal data and to use it for other purposes (namely transmitting it to other data controllers, e.g. other organisations).

To facilitate the right of data portability, we shall make available all applicable personal data to you in either of the following formats:

  • Email or;
  • Post

Where technically feasible, if requested, personal data shall be sent directly to another data controller.

All requests for copies of personal data shall be complied with within one month of your request (this can be extended by up to two months in the case of complex requests in the case of complex or numerous requests, and in such cases you will be informed of the need for the extension).

G.  Object to Personal Data Processing

You have the right to object to us processing your personal data based on legitimate interests (including profiling), direct marketing (including profiling), and processing for historical research and statistics purposes.

  • Where you object to us processing your personal data based on legitimate interests, we shall cease such processing forthwith, unless it can be demonstrated that the legitimate grounds for such processing override your interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.
  • Where you object to us processing your personal data for direct marketing (or profiling) purposes, we shall cease such processing forthwith.
  • Where you object to us processing your personal data for scientific and/or historical research and statistics purposes, you will be required, under the GDPR, to ‘demonstrate grounds relating to his or her particular situation’. We are not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

You also have the right to lodge a complaint with your local supervisory authority, details of which can be found on their website www.ico.org.uk/

H.  Automated Decision Making & Profiling

In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions under the GDPR, requesting human intervention, express your own point of view, and obtain an explanation of the decision from us.

This right does not apply in the following circumstances:

  • The decision is necessary for the entry into, or performance of, a contract between us and you;
  • The decision is authorised by law; or
  • Where you have given us your explicit consent.

Where we use personal data for profiling purposes, the following shall apply:

  • Clear information explaining the profiling will be provided, including its significance and the likely consequences;
  • Appropriate mathematical or statistical procedures will be used;
  • Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
  • All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

9. Data Protection Measures

We shall ensure that all employees, agents, contractors, or other parties working on our behalf comply with the following when working with personal data:

  • All emails containing personal data must be encrypted using SSL;
  • Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted;
  • Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
  • Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
  • Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted.  All temporary files associated therewith should also be deleted;
  • Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
  • Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using registered post;
  • No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of Linea requires access to any personal data that they do not already have access to, such access should be formally requested from Mike Gorshkov, telephone: 02920 775 910;
  • All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;
  • No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of Linea or not, without the authorisation of Mike Gorshkov, Managing Director. Telephone number 02920 775 910;
  • Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;
  • If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;
  • No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets and smartphones), whether such device belongs to Linea or otherwise without the formal written approval of Mike Gorshkov, telephone: 02920 775 910 and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;
  • No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of Linea where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to Linea that all suitable technical and organisational measures have been taken);
  • All personal data stored electronically should be backed up daily with backups stored offsite. All backups should be encrypted using SSL;
  • All electronic copies of personal data should be stored securely using passwords and 256 Bit AES Security;
  • All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by us is designed to require such passwords;
  • Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of Linea, irrespective of seniority or department.  If a password is forgotten, it must be reset using the applicable method.  IT staff do not have access to passwords.

10. Organisational Measures

We will ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

  • All employees, agents, contractors, or other parties working on behalf of Linea shall be made fully aware of both their individual responsibilities and Linea’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;
  • Only employees, agents, sub-contractors, or other parties working on behalf of Linea that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by Linea;
  • All employees, agents, contractors, or other parties working on behalf of Linea and handling personal data will be appropriately trained to do so;
  • All employees, agents, contractors, or other parties working on behalf of Linea and handling personal data will be appropriately supervised;
  • Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
  • The performance of those employees, agents, contractors, or other parties working on behalf of Linea and handling personal data shall be regularly evaluated and reviewed;
  • All employees, agents, contractors, or other parties working on behalf of Linea and handling personal data will be bound to do so in accordance with the principles of the GDPR and this and the Employee Data Protection Policy by contract;
  • All agents, contractors, or other parties working on behalf of Linea and handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of Linea arising out of this Policy and the GDPR;
  • Where any agent, contractor or other party working on behalf of Linea and handling personal data fails in their obligations under this Policy that party shall indemnify and hold Linea harmless against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

11. Transferring Personal Data to a Country Outside the EEA

We may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA. The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

  • The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
  • The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
  • The transfer is made with informed consent;
  • The transfer is necessary for the performance of a contract between you and us (or for pre-contractual steps taken at your request);
  • The transfer is necessary for important public interest reasons;
  • The transfer is necessary for the conduct of legal claims;
  • The transfer is necessary to protect your vital interests or other individuals where the data subject is physically or legally unable to give their consent; or
  • The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

12. Data Breach Notification

All personal data breaches must be reported immediately to the Data Protection Representative.

If a personal data breach occurs and that breach is likely to result in a risk to your rights and freedoms (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Representative must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

In the event that a personal data breach is likely to result in a high risk to your rights and freedoms, the Data Protection Representative must ensure that all affected are informed of the breach directly and without undue delay.

Data breach notifications shall include the following information:

  • The categories and approximate number of individuals concerned;
  • The categories and approximate number of personal data records concerned;
  • The name and contact details of our Data Protection Representative (or other contact point where more information can be obtained);
  • The likely consequences of the breach;

Details of the measures taken, or proposed to be taken, by Linea to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

13. Our Legal Bases for Processing Your Data

Under GDPR, the main grounds that we rely upon in order to process personal information of clients and candidates are the following:

A. Legitimate Interests

We will need to process your personal data for the purposes of our (or our Client’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected.

  • Candidate Data:  Our legitimate interests include responding to requests and enquiries from you directly or contacting you if you have posted your professional CV, or similar information, on a job board or professional networking site and your skill set matches one of our vacancies. In order for us to provide our recruitment services to you, we need to collect, process and share certain information with prospective employers. (Though we will seek consent before sharing your personal data). We carry out these processes so that we can function as a profit-making business, and to help you get the job you are looking for.
  • Client Data:  To ensure that we provide you with the best service possible, we store your personal data as well as vacancy information including records of our conversations, meetings and placements. We may also, occasionally, ask you to undertake a survey in order to optimise our customer experience. We consider these uses of your data to be necessary for our legitimate interests as an organisation providing recruitment services to you.
  • Supplier Data:  We use and store your personal data to facilitate the contract between us. We also hold your financial details, so that we can pay you for your goods or services. We deem all such activities to be within the range of our legitimate interests as a customer.
  • Referees and Emergency Contacts:  If a candidate or employee has provided your contact details as one of their referees, we use your personal data in order to contact you for a reference. We consider this to be necessary for our legitimate interests as an organisation offering recruitment services as well as employing people to join our own team. If a candidate or employee has given us your details as an emergency contact, we will only use these details for the purpose they were originally collected i.e. to contact you in the case of an accident or emergency.

Our legitimate interests also include optimising our website and customer experience, and ensuring that our operations are conducted in an appropriate and efficient manner.

B. Consent

Before transferring your personal data to a prospective employer, we will obtain your consent to the processing of your personal data. As we have mentioned, you have the right to withdraw your consent to these activities and this will not affect us assisting you in the future.

C. Entering or Performing a Contract

In order to meet contractual obligations that we may have in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data. We may share your information with our service providers if you are placed in a contract role but we will notify you before doing so.

D. Legal Claims

Sometimes it may be necessary for us to process personal data in connection with exercising or defending legal claims. 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.

14. Implementation of Policy

This Policy shall be deemed effective as of 17th May 2018.  No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved and authorised by:

Name: Mike Gorshkov
Position: Managing Director
Date: 17th May 2018
Due for review by: 19th February 2019

Signature