Section 1 – Identity of the data controller
First Achieve (“Us”, or “Ourselves”) protect the personal data of both candidates and clients (“Users”, “You”, or “Your”) in line with applicable Data Protection Regulation and adhere to the principles of providing you with clear information as to;
- What personal data we collect;
- How we process this data, and the reasoning behind this processing;
- Your rights as a data subject, including how you can access your personal data or request for your data to be deleted;
- How your data is stored and kept secure;
- Details regarding our cookies policy, and;
- Details of how you can contact ourselves in the case of any enquiries.
Section 2 – Your obligations, and the right to withdraw consent
Section 3 – Personal data which we collect from You
At your first point of interaction with First Achieve, we take the following details;
- First Name
- Email Address
- Curriculum Vitae (CV)
These details are used primarily for contact purposes in the first instance.
Subsequent to this, we may collect any of the following further information from you for the sole purposes of fulfilling our services to you in the best fashion. These details will differ between if you are using our services in order to find a candidate for a vacancy (defined hereafter as an “client”) or if you are an individual wishing to use our service in order to find a work role (defined hereafter as a “candidate”).
As a client, we will collect and record the following further information;
- Information regarding the nature of your business and client requirements.
- Payment details.
- Your feedback in regards to any candidates referred to you by us.
- Records of dealings and transactions, including any payment details, and any contractual agreements undertaken between you and us.
As a candidate, we will collect and record any further information which you may include about yourself in any Curriculum Vitae (CV) which you submit to ourselves, as well as any information contained in any references provided, and any information which you provide through face-to-face interviews with ourselves or via a phone call.
- Date of birth
- Education and qualification history
- Job history
- Documentation to verify your identity and eligibility to work in the United Kingdom (including but not limited to copies of your passport, driving licence, and/or any supporting documentation such as a Visa)
- National Insurance or payment information.
- Contact details of any referees
- Any sensitive personal information which may be relevant to your job suitability (for example, any health-related information), and recordings of phone calls.
Section 4 – How do we obtain your personal data?
The majority of personal data which we collect is volunteered from you to us.
The only circumstances in which we may obtain information about you indirectly are if you, as a candidate, have uploaded your details to a third-party platform with whom we have a contract which grants us access to that information for the sole purpose of informing you of a job vacancy to which you may be suited.
We may also have found your details through a public domain social networking platform to which you have volunteered your personal data which would be relevant to our stated purpose of processing (see Section 4).
Section 5 – How and why we process your personal data
We process your personal data in the following fashions;
- To perform an assessment of candidate suitability for any role or opportunity advertised, and subsequently supply candidate details to clients in relation to these role(s).
- In order to notify candidates of any vacancies which may be suitable or of interest to you.
- To retain a record of all correspondence (with candidates), and details of financial transactions (with clients)
- For the purpose of marketing communications, if you have opted-in to receiving such communications.
- Correspondence with both candidates and clients will be evaluated for quality by First Achieve, for the purpose of monitoring compliance with this privacy notice, and for determining staff training and system requirements.
We undertake all of the above processes as a legitimate business interest for the purpose of operating a recruitment business for the use of both candidates and clients. We also process your personal data in order to comply with any statutory provision which regulates our service which we provide to you, including the Conduct of Employment Agencies and Employment Business Regulations (2003), which requires us to obtain all sufficient information prior to introducing any candidate to an client which would allow us to confirm the identity of the candidate, and the relevant qualification, skills and experience of the candidate.
Section 6 – Personal data which we share with others
We would be required to share your personal data with authorities in the event of any applicable legal requirement, such as fraud/crime prevention, or co-operating with regulatory authorities such as HMRC or the Information Commissioners Office.
In the event of a sale, merger, transfer of assets, entering receivership, or liquidation, First Achieve may need to transfer your information to a third party. This will be communicated to you in the event, and you will be able to withdraw consent for future processing and request deletion of data in line with your rights as a data subject.
Section 7 – Retention timeframes, and your right to be forgotten
First Achieve will only retain data for the necessary time to complete the task that the data was collected for, or to meet our legal obligations.
- You may request that your Personal Data be anonymised in the following circumstances:
- Where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected/processed.
- When you withdraw consent, if consent is being used as the Legal Basis for Processing.
- If you object to the Processing and there is no overriding Legitimate Interest or Legal Obligation to continue the Processing.
- The Personal Data was unlawfully processed.
- The Personal Data has to be erased to comply with a legal obligation
If you wish for your data to be deleted at any point sooner than these stated time-frames, please contact the Data Protection Officer through the process outlined in Section 1. The Data Protection Officer will review what personal data we hold about you and delete the data if it is possible to do so. If there is a legal basis for retaining the data, you will be contacted by the Data Protection Officer within one calendar month confirming the legal reasoning as to why the data has not been removed.
Section 8 – Your rights as a data subject
Requested information will be provided within one calendar month from the SAR being received by First Achieve. If for any reason First Achieve can not meet this deadline (for example, if the requests made are numerous and complex), you will be informed of this within the initial one month window, with an explanation as to why the data has not yet been provided, along with a firm estimation of when the data will be collated and prepared for sending to you.
No charge is applied to an SAR, however in the event of requests being manifestly unfounded, excessive, or repetitive in nature, First Achieve may charge a reasonable fee to complete the SAR. This fee will be based purely on the administrative costs incurred in providing the requested information and will never exceed £10.
If you are in any way dissatisfied with how First Achieve has handled your personal data, and are dissatisfied with your response from ourselves after raising an SAR or any other concern with ourselves through firstname.lastname@example.org, you have the right to make a complaint to the Information Commissioners Office (ICO), with whom we comply in any enquiry or investigation which they may make.
Section 9 – Automated decision making and profiling
First Achieve do not use any automated systems in order to make decisions regarding a candidate’s suitability for a role, nor complete any profiling which would have any legal effect on the user.
When you visit our website, we use small text files (“cookies”) to increase the performance of the website, offer a more personalised service to you, and analyse user behaviour for the sole purpose of improving website functionality. The cookies which we use on our site fulfil the following purposes;
- Allowing visitors to use certain functions of the website and set preferences.
- To improve user experience and increase functionality (for example, to stop users from being shown the same message on more than one occasion)
- To monitor and collect information about user behaviour on the website, for the purpose of analysis and tracking.
We also use Google Analytics cookies in order to track and report on website traffic.