WEBSITE PRIVACY STATEMENT

How we collect, use, and store your data 

Organisation name: Kapstan Recruitment Ltd 

Reference: ZA911361 

Privacy Notice Last Updated: 11 February 2021

Introduction
This Privacy Notice applies to all data collections and other data processing of Kapstan Recruitment Ltd. For the purposes of this Privacy Notice any references to Kapstan Recruitment (or “us” or “we” or “our” or ”Kapstan”) means Kapstan Recruitment Ltd.

At Kapstan we take your privacy seriously, this Privacy Notice explains how we treat your personal data to maintain your privacy. It describes how we collect, use and process your personal data, explaining what we do with it whether we are in the process of helping you find a job, continuing our relationship with you after finding you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates or you are a Website Visitor.

This Privacy Notice applies to the personal data of Candidates, Clients, Contractors, Staff, Suppliers, Website Visitors and other people whom we may contact in relation to our Candidates or whom they have indicated as an emergency contact. It also applies to the emergency contacts of our Staff.

Kapstan Recruitment Ltd reserves the right to update this Privacy Notice at any time, please review the “Last Updated” details at the top of this page to determine when this Privacy Notice was last updated. Any change to this Privacy Notice will become effective on the “Last Updated” date indicated above. Kapstan Recruitment Ltd will make every effort to communicate any significant changes to you via email and/or by posting a notice on Kapstan Recruitment’s Site. Your continued use of Kapstan Recruitment Ltd’s services will be deemed as acceptance of any amended Privacy Notice.If you are dissatisfied with any aspect of our Privacy Notice, you may have legal rights and, where relevant, we have described these as well.


How We Use Your Personal Data

Kapstan Recruitment Ltd collect your personal data in order to facilitate the recruitment process, you are under no obligation to provide your personal data, however, if you do not provide your personal data we may not be able to provide you with certain services. We only ask for details that will genuinely help us to help you, we do not collect more information that we require to fulfil our stated purposes and will not retain it for longer than is necessary.


It is not our policy to seek sensitive personal data unless required for further recruitment purposes, legally required, or reasonably necessary for an ongoing relationship with you. Sensitive data includes data concerning race or ethnic origin, physical or mental health, sexual orientation, religious beliefs, political opinion, trade union membership, or criminal records and proceedings. We, therefore, suggest that you do not offer sensitive personal data of this nature unless specifically requested to do so. If you do provide sensitive personal data for any reason, we accept this as your consent to use such data in the ways described in this Privacy Notice. The personal data we hold is dependent upon your relationship with us, the information below describes the personal data held, how it is collected and used, the systems it is held in, the period we hold it for, who it is shared with, and the lawful basis for processing. The information described below is in addition to any personal data we are required by law to process in any given situation.

Unless otherwise stated Kapstan Recruitment is the Data Controller for the personal data you provide. If you have any queries about how we handle your personal data, please contact us at Hello@KapstanRecruitment.co.uk

Candidates
What Personal Data We Hold
Dependent on the circumstances and requirements we may collect some or all of the personal data listed below to enable us to offer you employment opportunities that are tailored to your interests, skill set, experience and expectations.
Name
Date of Birth
Contact Details;
Address
Telephone Number (Home)
Telephone Number (Work)
Telephone Number (Mobile)
Email Address (Personal)
Email Address (Work)
LinkedIn Profile
Job Title
Current Employer;
Remuneration
Pension
Benefits
Desired Salary/Rate
Experience
Qualifications
Avatar
Photo Identification;
Copy of Driving License
Copy of Passport
Video
Telephone Conversation Voice Recordings
Please note the above list of personal data we may collect is not exhaustive.

How We Collect Personal Data
We collect your personal data in three primary ways:

Personal data provided by you, the Candidate;
Personal data we receive from other sources; and
Personal data we collect automatically.

Personal Data Provided by You
Kapstan Recruitment Ltd needs to know certain information about you to be able to provide a tailored service. This personal information enables us to provide you with the best opportunities and to improve your job search experience with us.There are a number of ways you can share your personal information with us. These include, but are not limited to:
Entering your details on the Kapstan Recruitment Ltd website as part of the registration process;
Leaving a hard copy of your CV at a Kapstan recruitment event, job fair or office;
Emailing your CV to a Kapstan Recruitment Ltd consultant or being interviewed by them; or
Applying for jobs through a job aggregator, which then redirects you to the Kapstan Recruitment Ltd website

Personal Data We Receive from Other Sources
In addition to personal data received directly from you Kapstan Recruitment Ltd also receive personal data about Candidates from other sources. These may include personal data received in, but not limited to, the following situations:Your referees may share personal information about you with us;
Our Clients may share personal information about you with us;
We may obtain personal information about you from searching for potential Candidates from third-party sources, such as LinkedIn and other job sites; and
If you “like” our page on Facebook or “follow” us on Twitter we will receive your personal information from those sites.


Personal Data We Collect Automatically
When accessing our website or if you read or click on an email from us we may collect your data automatically, or through you providing it to us.

How We Use Personal Data
We use the personal data we hold about you to provide and personalise the services we offer, enabling them to be more relevant and useful to you. We use it in three primary ways:

Recruitment activities;
Marketing activities; and
To help us establish, exercise or defend legal claims.

Recruitment Activities
Our main area of work is recruitment, and as a Candidate, your personal data is processed for the purposes of providing you with work-finding services. This includes, but is not limited to:
Contacting you about job opportunities;
Assessing your suitability for those job opportunities;
Updating our databases;
Putting you forward for job opportunities (sending your information to Clients); and
Developing and managing our services and relationship with you.
Marketing Activities
We may, from time to time, send you information we think you may find interesting. We may wish to use your personal information for purposes including, but not limited to:The development and marketing of other products and services;
Marketing our full range of recruitment services to you;
Sending you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think may be of interest to you; and
Displaying promotional excerpts from your details on Kapstan Recruitment Ltd’s website(s) as a success story (only where we have obtained your express consent to do so).
We need your consent for some aspects of these activities which are not covered by our legitimate interests and, depending on the situation, we’ll ask for this via an opt-in. If you have opted out from our marketing communications, either via the unsubscribe link in the footer of marketing emails or through your website profile, it is possible that your personal data may be recaptured from public sources in an unconnected marketing campaign. While we will endeavour to ensure this does not happen there may be instances, from time to time, where it does and would appreciate your understanding in these instances. Our marketing is based on what we think will serve our Candidates best.

To Help Us Establish, Exercise, or Defend Legal Claims
In some cases, we may be required to use your data for the purpose of investigating, reporting, and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.


How Long We Keep Your Data For (Retention)
We will keep your personal data for a period of three years after our last meaningful contact with you (or our last meaningful contact with the company or entity that supplies your services if they are provided via a third-party company or entity). Different laws may require us to keep your personal data for different periods of time, where a law requires we keep your personal data for a period in excess of three years your personal data will be kept the period required by law.“Meaningful contact” means, for example, written or verbal communication between us and you or where you are actively using our online services, including, but not limited to, uploading your updated CV to our website. We also consider communication from you regarding potential roles, either written or verbal, or clicking through from, or replying to, any of our marketing emails as meaningful contact.

Who We Share Your Personal Data With
Where appropriate, and in accordance with local laws and requirements, we may share your personal data with the following categories of people:

Any of our group companies; Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;

Tax, audit, or other authorities, we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);

Third-party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);

Third-party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Marketing technology platforms and suppliers;

Potential employers and other recruitment agencies/organisations to increase your chances of finding employment;

Third-party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job;

Managed Service Provider (MSP) suppliers as part of our clients’ MSP programmes;

Third-parties we have retained to provide services such as reference, qualification and criminal conviction checks, to the extent that these checks are appropriate and in accordance with local laws; and If Kapstan Recruitment merges with or is acquired by another business or company in the future (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

Lawful Basis for Processing

Article 6 of the General Data Protection Regulation (GDPR) requires that we process all personal data lawfully, fairly and in a transparent manner.

Article 6(1)(f) states that Kapstan Recruitment Ltd can process your data where “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 the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”

In simpler language this is where Kapstan Recruitment has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.

As a Candidate we believe it is reasonable to expect us to collect and use your personal information to provide recruitment services to you, to share your personal information with prospective employers and compare your skills against our current vacancies where you have either provided us with your information directly, posted your CV information on a job board or on professional networking sites. Once it looks like you may be offered a position with a prospective employer, they may want to check any information you have provided or to confirm your qualifications, experience or references. The providing of this information to prospective employers is required to help you, and other Candidates, get the jobs you deserve and allows us to function as a profit-making recruitment business.

We think it’s reasonable to process your personal data to provide a tailored recruitment service, offering you, the Candidate, a more pleasant job search experience and ensuring you receive the most appropriate content for your job search.

In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

While we don’t believe any of the above activities prejudice you in any way – they enable us to provide the service you have engaged us for – you have the right to object to us processing your data on this basis.

Clients

What Personal Data We Hold
The data we collect about Clients is actually very limited. Dependent on the circumstances and requirements we may collect some or all of the personal data listed below to enable us to fulfil our obligations to you as a client.

Name
Contact Details;
Address
Telephone Number (Home)
Telephone Number (Work)
Telephone Number (Mobile)
Email Address (Personal)
Email Address (Work)
LinkedIn Profile
Job Title
Current Employer
Telephone Conversation Voice Recordings
Video
Please note the above list of personal data we may collect is not exhaustive.

How We Collect Personal Data
We collection your personal data in three primary ways:

Personal data provided by you, the Client;
Personal data we receive from other sources; and
Personal data we collect automatically.

  1. Personal Data Provided by You
    Kapstan Recruitment Ltd needs to know certain information about you and your business to ensure that you have the best staff for your business.
    There are a number of ways you can share your personal information with us. These include, but are not limited to:
    Where you contact us proactively, usually by phone or email; and/or
    Where we contact you, usually by phone or email, or through our consultants’ business development activities.
  2. Personal Data We Receive From Other Sources
    In addition to personal data received directly from you Kapsan Recruitment Ltd also receive personal data about Clients from other sources. These may include personal information received in, but not limited to, the following situations:

Due diligence checks;
Marketing intelligence;
Delegate lists at relevant events; and
Other third parties, for example Candidates that provide your details to act as a referee for them.

  1. Personal Data We Collect Automatically
    When accessing our website or if you read or click on an email from us we may collect your data automatically, or through you providing it to us.
    How We Use Personal Data
    We use the personal data we hold about you to provide and personalise the services we offer, enabling them to be more relevant and useful to you. We use it in three primary ways:

Recruitment activities;
Marketing activities; and
To help us establish, exercise or defend legal claims.

  1. Recruitment Activities
    Our main area of work is recruitment, and as a Client, your personal data is processed for the purposes of providing you with employee-finding services. This includes, but is not limited to:

Providing you with Candidates, Recruitment Process Outsourcing (RPO) services and MSP programmes;
To contact you in relation to recruitment activities;
Keeping records of our conversations and meetings, to provide targeted services to you; and
Processing your data for the purpose of targeting appropriate marketing campaigns.

  1. Marketing Activities
    We may, from time to time, send you information we think you may find interesting. We may wish to use your personal information for purposes including, but not limited to:

The development and marketing of other products and services;
Marketing our full range of recruitment services to you;
Sending you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think may be of interest to you; and displaying promotional excerpts from your details on Kapstan Recruitment Ltd’s website(s) as a success story (only where we have obtained your express consent to do so).
We need your consent for some aspects of these activities which are not covered by our legitimate interests and, depending on the situation, we’ll ask for this via an opt-in.

If you have opted out from our marketing communications, either via the unsubscribe link in the footer of marketing emails or through your website profile, it is possible that your personal data may be recaptured from public sources in an unconnected marketing campaign. While we will endeavour to ensure this does not happen there may be instances, from time to time, where it does and would appreciate your understanding in these instances.

  1. To Help Us Establish, Exercise, or Defend Legal Claims
    In some cases, we may be required to use your data for the purpose of investigating, reporting, and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

How Long We Keep Your Data For (Retention)
We will keep your personal data for a period of three years after our last meaningful contact with you. Different laws may require us to keep your personal data for different periods of time, where a law requires we keep your personal data for a period in excess of three years your personal data will be kept for the period required by law.

“Meaningful contact” means, for example, written or verbal communication between us and you or where you are actively using our online services. We also consider communication from you regarding potential roles, either written or verbal, or clicking through from, or replying to, any of our marketing emails as meaningful contact.

Who We Share Your Personal Data With
Where appropriate, and in accordance with local laws and requirements, we may share your personal data with the following categories of people:

Any of our group companies; Tax, audit, or other authorities, we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third-party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third-party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Marketing technology platforms and suppliers; and

If Kapstan Recruitment merges with or is acquired by another business or company in the future (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

Lawful Basis for Processing
Article 6 of the General Data Protection Regulation (GDPR) requires that we process all personal data lawfully, fairly and in a transparent manner.

Article 6(1)(f) states that Kapstan Recruitment Ltd can process your data where “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 the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”

In simpler language this is where Kapstan Recruitment Ltd has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.

As a Client we believe it is reasonable to expect us to collect and use your personal information to provide the best recruitment services to you.

In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

While we don’t believe any of the above activities prejudice you in any way – they enable us to provide the service you have engaged us for – you have the right to object to us processing your data on this basis.

Website Visitors
We may gather information and statistics collectively about all visitors to our website and the Kapstan Recruitment Ltd. We only use such data in the aggregate form. This information helps us determine what is most beneficial for our users and how we can continually improve our online services to create a better overall experience for our users

Access

You have the right at any time to ask us for a copy of the information supplied by you that we hold. We may ask you to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request but only as detailed below and will give you reasons for doing so.
If you would like to make a request for information, please contact; Hello@KapstanRecruitment.co.uk

You also have the right to ask Kapstan Recruitment to stop using your information. However, if this involves a request for deletion of your file, please be aware that we may not be required or able to do so, particularly where your file also holds information about our clients or financial information that we need to keep for periods of up to six years, i.e. that relate to tax matters on Contracts etc. Where we are unable to comply with your request, we will provide reasons why and agree these with you.

Other Third-party websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Internet-based transfers

Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Therefore, by browsing our website and communicating electronically with us, you acknowledge and agree to our processing of personal data in this way.

Your Rights

Kapstan Recruitment Ltd aims to meet the highest standards when collecting and using personal information.

If at any time, you have questions or concerns about Kapstan Recruitment or Personnel’s Privacy commitment, please feel free to e-mail us at Hello@KapstanRecruitment.co.uk or call our office to speak to one of our Team.

If you wish to complain about this policy or any of the procedures set out in it please contact us via Hello@KapstanRecruitment.co.uk

Cookies Policy
Cookies are small text files that are placed on your computer, smartphone, or tablet by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies are used by nearly all websites and do not harm your system.
If you leave a comment on our site you may opt in to saving your name, email address, and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
Rules on cookies

In order to comply with GDPR we must:
tell you the cookies are present;
explain what the cookies are doing and why; and
get your consent to store a cookie on your device.

How Kapstan Recruitment uses cookies
Cookies are used in order to make our website work, to make it work more efficiently and to provide us with information when you apply for a job.
If you do not consent to Kapstan Recruitment storing your personal data or setting up a personal registration for you, please do let us know asap.

How to Contact Us
You can contact us by email, telephone or in writing:
Email: Hello@KapstanRecruitment.co.uk
Telephone: 0203 9836 249

SECURITY AND DATA PROTECTION POLICY
As a recruitment company, Kapstan Recruitment processes personal data in relation to its own staff, candidates, and individual client contacts. It is vitally important that we abide by the principles of the Data Protection Act 1998 set out below.


Kapstan Recruitment holds data on individuals for the following general purposes:
Staff Administration
Advertising, marketing, and public relations
Accounts and records
Administration and processing of candidate personal data for the purposes of work-finding services
The Data Protection Act 1998 requires Kapstan Recruitment as data controller to process data in accordance with the principles of data protection. These require that data shall be:

Fairly and lawfully processed
Processed for limited purposes
Adequate, relevant and not excessive
Accurate
Not kept longer than necessary
Processed in accordance with the data subjects rights 7. Kept securely 8. Not transferred to countries outside the European Economic Area without adequate protection.
Personal data means data, which relates to a living individual who can be identified from the data or from the data together with other information, which is in the possession of or is likely to come into possession of, Kapstan Recruitment.

Processing means obtaining, recording or holding the data or carrying out any operation or set of operations on the data. It includes organising, adapting and amending the data, retrieval, consultation and use of the data, disclosing and erasure or destruction of the data. It is difficult to envisage any activity involving data, which does not amount to processing. It applies to any processing that is carried out on computer including any type of computer however described, main frame, desktop, laptop, palm top etc.

Data should be reviewed on a regular basis to ensure that it is accurate, relevant and up to date and those people listed in the appendix shall be responsible for doing this.

Data may only be processed with the consent of the person whose data is held. Therefore if they have not consented to their personal details being passed to a third party this may constitute a breach of the Data Protection Act 1998.

By instructing Kapstan Recruitment to look for work and providing us with personal data contained in a CV work-seekers will be giving their consent to processing their details for work-finding purposes. If you intend to use their data for any other purpose you must obtain their specific consent.

However caution should be exercised before forwarding personal details of any of the individuals on which data is held to any third party such as past, current or prospective employers; suppliers; customers and clients; persons making an enquiry or complaint and any other third party.

As a recruitment business we are bound by Regulation 28 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003 to obtain the prior consent of an individual before disclosing any information relating to them other than for the purposes of finding them work, or in relation to legal proceedings or to a professional body of which they are a member. Prior written consent must be obtained before disclosing any information relating to an individual work-seeker to their current employer.

Data in respect of the following is “sensitive personal data” and any information held on any of these matters MUST not be passed on to any third party without the express written consent of the individual: Any offence committed or alleged to be committed by them.

Proceedings in relation to any offence and any sentence passed
Physical or mental health or condition
Racial or ethnic origins
Sexual life
Political opinions
Religious beliefs or beliefs of a similar nature
Whether someone is a member of a trade union
From a security point of view, only those staff listed in the appendix should be permitted to add, amend or delete data from the database. However all staff are responsible for notifying those listed where information is known to be old, inaccurate or out of date. In addition all employees should ensure
that adequate security measures are in place.

For example:

Computer screens should not be left open by individuals who have access to personal data
Passwords should not be disclosed
Email should be used with care
Personnel files and other personal data should be stored in a place in which any unauthorised attempts to access them will be noticed. They should not be removed from their usual place of storage without good reason.
Personnel files should always be locked away when not in use and when in use should not be left unattended
Any breaches of security should be reported to the Information Security Manager and may be treated as a disciplinary issue.
Care should be taken when sending personal data in internal or external mail
Destroying or disposing of personal data counts as processing. Therefore care should be taken in the disposal of any personal data to ensure that it is appropriate. For example, it would have been more appropriate to shred sensitive data than merely to dispose of it in the dustbin.
It should be remembered that the incorrect processing of personal data e.g. sending an individual’s details to the wrong person; allowing unauthorised persons access to personal data; or sending information out for purposes for which the individual did not give their consent, may give rise to a breach of contract and/or negligence leading to a claim against Kapstan Recruitment for damages from an employee, work-seeker or client contact. A failure to observe the contents of this policy will be treated as a disciplinary offence.

Data subjects, i.e. those on whom personal data is held, are entitled to obtain access to their data on request and after payment of a fee. All requests to access data by data subjects i.e. staff, members, customers or clients, suppliers, students etc should be referred to the Managing Director whose details are also listed on the appendix to this policy.

Any requests for access to a reference given by a third party must be referred to your line manager and should be treated with caution even if the reference was given in relation to the individual making the request. This is because the person writing the reference also has a right to have their personal details handled in accordance with the Data Protection Act 1998, and not disclosed without their consent. Therefore when taking up references an individual should always be asked to give their consent to the disclosure of the reference to a third party and/or the individual who is the subject of the reference if they make a subject access request. However if they do not consent then consideration should be given as to whether the details of the individual giving the reference can be deleted so that they cannot be identified from the content of the letter. If so the reference may be disclosed in an anonymous form.

Finally it should be remembered that all individuals have the following rights under the Human Rights Act 1998 and in dealing with personal data these should be respected at all times:

Right to respect for private and family life [Article 8]
Freedom of thought, conscience and religion [Article 9]
Freedom of expression [Article 10]
Freedom of assembly and association [Article 11]
Freedom from discrimination [Article 14]