Elizabeth Norman Limited (ENI) are committed to protecting and respecting your privacy.
This notice sets out the basis on which personal data we collect from or about you, will be processed by ENI.
Your rights under the GDPR are set out in this notice and apply from the 25th of May 2018.
Please read the following carefully 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 Elizabeth Norman Ltd (ENI) of 2nd Floor, 68-69 St Martin’s Ln, Covent Garden, London WC2N 4JS
Our nominated representative is Liz Norman, email@example.com
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. We also provide the following additional services; consultancy, outsourcing, mentoring/advice and events. 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; and
Employees, consultants and temporary workers.
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you
This is information about you that you give us by filling in forms on our site www.elizabethnorman.com or by corresponding with us face to face, by phone, email or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, and enter a competition, promotion or survey.
The information we collect about you may include your name, address, private and corporate email address and phone number, curriculum vitae and photograph, financial information, email correspondence, details about current/past employment and interview notes including employment preferences. It may also include compliance documentation (such as passports and visas) and references and links to your profiles available in the public domain e.g. LinkedIn, Twitter, Facebook or corporate websites.
Privacy notice related to all accounts set up on our ENI website
- Any account set up in the ENI website is directly managed by the account holder and will provide the following personal data; name, email address, current job role, contact phone number with a further optional choice to provide a link to a LinkedIn profile or upload a CV.
- We collect this data so the account holder can a) set up the account b) apply to jobs that ENI advertise either directly or, through the job monitoring service that the account function allows the account holder to set up.
- This data will be held for a maximum of 12 months on encrypted servers upon which a reminder service, by email, will allow the account holder to keep the account or, if not responded to, the account will be automatically deleted. At any point the account holder can delete their own account within this time frame and is set up as a self-management service
- This data is only accessible by Heyoo LTD, our website managers, the marketing manager and data protection officers at ENI. This access is to allow us to support you manage the process of opening and closing accounts. This data is not accessible to any consultant for the purposes of contacting account holders about new opportunities. This data is not held on any other 3rd party software, unless an account holder becomes registered directly with a consultant at ENI. In these scenarios the data protection policies apply to being registered with ENI, which are also found in this document
- All account holders can opt in or out of marketing directly, so the choice is with the account holders
- You can contact the data protection officer at any time about your account as per the policy process which is listed in this document
Information we collect about you when you visit our website
ENI use Google analytics but we cannot identify individual information from the reports.
We will process any information you choose to give us via the website, as covered by the rest of this policy. In addition, we have your login information.
Information we obtain from other sources
ENI will from time to time obtain information about individuals previously unknown to ENI from third parties. For example, job boards, or referrals/recommendations from others in the industry. If you are introduced to ENI in this way, we will inform you by sending you this privacy notice, within a maximum of 30 days of collecting the data.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
- The introduction of candidates to our clients for the purpose of temporary or permanent engagement. Our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies. With this in mind, we have a community of contacts that we research and contact on a regular basis.
- To carry out our obligations to candidates on our payroll, arising from contracts between you and ENI.
- To provide you with the information, products and services that you request from us or we think will be of interest to you because they are relevant to your career or to your organisation
Our legal basis for the processing of personal data is our legitimate business interest, described in more detail below, although we will also rely on contract and legal obligation for specific uses of data.
We will rely on contract if we are negotiating or have entered into a temporary placement contract with you or your organisation to work for a third party whilst on our payroll.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations; for example a visa to work in a particular country.
Our legitimate business interests
Our legitimate business interests in collecting and retaining your personal data are described below:
- As a recruitment business and 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 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 and satisfy legislative requirements, financial records, surveys, and consultancy.
Other uses we may make of your data
We will use this information:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- To send newsletters and other marketing information/invitations from ENI and our associated companies.
Disclosure of your information inside and outside of the EEA
We may share your personal information with:
Selected third parties including:
- Clients for the purpose of introducing candidates;
- 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.
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 ENI or substantially all of its assets were acquired by a third party, in which case personal data held by it about its customers would 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, other agreements; or to protect the rights, property, or safety of ENI, our customers, or others.
The lawful basis for the third party processing may 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, or payroll advisor/provider.
- For the purpose of a contract in place to work with us on recruitment or consultancy services.
- To fulfil legal obligations.
Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. By submitting your personal data, you agree to this transfer, storing or processing. ENI will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
The information you provide to us is currently stored on our secure servers, based in our offices at 2nd Floor, 68-69 St Martin’s Ln, Covent Garden, London WC2N 4JS, on our website, on our CRM system which is held on the cloud by Bullhorn, on our accounting and banking systems and on paper records. We will shortly be moving to Microsoft Cloud and will no longer have a server.
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.
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 policy and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
ENI is keen to ensure the data we have on you is current and accurate. To do this we do the following:
- You can log into the website and update your registration details.
- Prior to making an introduction we discuss the opportunity and check that we have current information about you.
- We keep in touch from time to time, so you can let us know of changes to your personal data
- ENI follow social media about the industry.
- ENI welcome updates from all our contacts via email to your consultant or telephone 0207 836 3311.
We segregate our data so that we keep different types of data for different time periods. 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 retain data in accordance to the minimum retention periods for certain types of data, including:
- Records under the Conduct Regs – 1 year from last contact with candidate.
- Right to work checks – 2 years after end of employment.
- Payroll/wage records – 6 years from financial year-end.
- PAYE records – 3 years from the end of the applicable tax year.
You can visit the ICO website for some guidance ad guidelines on retention: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/principles/storage-limitation/
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to opt out of receiving marketing information, by clicking on the unsubscribe link on the email you receive when you register (it’s also on the bottom of other correspondence for example emails regarding newsletters). You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
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
- 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).
<liObject 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/
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.
A subject access request should be submitted to email@example.com
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 email. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Liz, firstname.lastname@example.org