Operational Privacy Notice

Privacy Notice

Prospective Candidate / Candidate, Client and Supplier Privacy Notice (updated 22/05/18)

1. Scope
Our Privacy Notice describes the ways we collect your personal information and governs how we will deal with it. We aim to ensure that any personal information we obtain and use will always be held, used and transmitted in compliance with the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together referred to as the ‘Data Protection Laws’)

Where this Privacy Notice contains hyperlinks to other pages on our website, we recommend you click on those links as they may contain additional important details about our RTC Group Data Protection Policy which governs everything we do. ATA Recruitment is part of the RTC Group of companies.

The website containing this Privacy Notice may contain links to third parties’ websites. ATA Recruitment Ltd assumes no responsibility for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those websites before either agreeing to their terms or using those websites.

This Privacy Notice applies with immediate effect to all data collected from data subjects, (Including work seekers, clients, suppliers or interested 3rd parties) either through the ATA Recruitment website or any other means.

ATA Recruitment Ltd may occasionally amend this Privacy Notice to reflect regulatory requirements and changes in our information collection and disclosure practices. Any new Privacy Notice will automatically be effective when it is published on the website. You should, therefore, return here regularly to view our most up to date RTC Group Data Protection Policy. We also advise you to print a copy for your records.

The location of the Privacy Notice will be displayed or hyperlinked to any forms that collect Personal Information and on all ATA Recruitment invoices and remittances.

2. Responsibilities
The RTC Group Data Protection Representative has overall responsibility for ensuring that this notice is applicable, compliant and in accordance with the RTC Group Data Protection Policy. The ATA Recruitment Compliance & Audit Manager is responsible for ensuring that the contents of the notice are implemented on behalf of the company.

All employees/staff of ATA Recruitment who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and where applicable, their consent to the processing of their data is secured.

3. Privacy Notice

3.1 Who are we?
ATA Recruitment Limited is part of the RTC Group Ltd.

ATA is a leading UK provider of recruitment services for engineering and manufacturing industries. Our in-depth knowledge of these sectors and the specific disciplines within them ensures we deliver tailored solutions to meet the individual needs of every client requirement.

As part of our commitment to protecting our candidates, employees, clients, suppliers and 3rd party’s data, we have implemented a stringent Information Security Management system to protect both the security and integrity of the data we process.

As part of our commitment to managing individual’s rights, we have appointed a Data Protection Representative (DPR), responsible for all Data Protection activities.

Our Data Protection Representative (DPR) can be contacted directly here:
• dpr@ata-recruitment.co.uk
• 01332 861 862

3.2 What information do we collect?

Personal data type Source Legal Basis
Contact name, social media profile (In the public domain), job title, previous experience) Social media profiles/3rd party job boards Legitimate interest/contract
Contact Information, such as name, address and telephone number Your submitted CV or details via our website / 3rd Party Job Boards/telephone business development sources, referrals, supplier details Legitimate interest/contract
Online contact information, such as your email address Social media profiles/Your submitted CV or details via our website / 3rd Party job boards business development sources, referrals, supplier details Legitimate interest/contract
A copy of your CV Social media profiles/your submitted CV or details via our website / 3rd party job boards Legitimate interest/contract
Other personal information such as your preferred employment requirements Your submitted CV/details via our website or personal interaction Legitimate interest/contract
Personal health data that may be required from an occupational health screening perspective to confirm suitability for a role. Personal interaction Legitimate interest/contract/consent
Right to work in the UK or required region Personal interaction/submitted document(s) Legitimate interest/contract
Navigation and click-stream data, the time of accessing the website, duration of your visit, pages and job vacancies you viewed or searched for Our website Legitimate interest/contract
Information from cookies or web beacons Our website Legitimate interest/contract
Your requested restrictions on our data processing such as preferred employers Personal interaction/your submitted CV or details via our website Legitimate interest/contract
Your Subject Access Requests Personal interaction/email/telephone conversation or in writing Legitimate interest/contract
Details pertaining to our Equality and Diversity policies Personal interaction consent

It may be necessary for us to collect data, which under Data Protection Law is classified as special categories of personal data.

The special categories of personal data referred to within the EU GDPR are;
• Racial
• Ethnic origin
• Political opinions
• Religious beliefs
• Philosophical beliefs
• Trade union membership
• Genetic data
• Biometric data
• Health data
• Data concerning a natural person’s sex life
• Sexual orientation
• Other

It is anticipated that the only special categories of personal data required from a job seeker will be for the purposes of health screening in very specific circumstances, in accordance with our Equality and Diversity policy where it will be anonymised and where authorised by law and criminal record checks. Consent will always be sought prior to this data being stored and processed.

3.3 How we collect your information if you are a jobseeker or prospective job seeker
ATA Recruitment Ltd obtains information from you in three ways:

A) Submitting your details
If you wish to apply for a vacancy online or submit your details to one of our consultants, we may ask you for you your contact information and/or CV details and/or job specification details as you proceed through the stages of the contact form or the conversation.

B) Automatic collection
Like most websites, our website uses cookies and web beacons to enhance your visitor experience. Please visit our website privacy notice for further details.

C) Information from third parties
ATA Recruitment Ltd may also obtain information about you directly from third parties, such as 3rd party job boards, social media sites and CV websites. ATA Recruitment Ltd will use this information to update our database records. If we have found your details on a social media website, they will only be retained during the process of establishing your consent for us to contact you. If you do not require our assistance in the job market, your details will be removed from our systems.

3.4 How we collect your information if you are client, prospective client, supplier or prospective supplier
ATA Recruitment Ltd obtains information from you in three ways:

A) Submitting your details
If you submit your details to us as a contact to enable us to manage a contractual obligation or provide information on our services or your products/services.

B) Automatic collection
Like most websites, our website uses cookies and web beacons to enhance your visitor experience. Please visit our cookie policy for further details.

C) Information from third parties
ATA Recruitment Ltd may also obtain information about you directly from third parties, such as Social Media sites, referrals, your own company website. If we have found your details via third party, and we do not require them for contractual purposes they will only be retained during the process of establishing your consent for us to contact you.

Independent of how we collect your data, we will always ensure that you have access to the relevant Privacy Notice.

If we have gathered your information from a third-party we will always seek authorisation from you to store and process your data.

Additional terms and conditions associated with using our website, including our use of cookies, can be found here.

If you want to disable cookies you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.

3.5 What will we do with your information if you are a job seeker or potential job seeker?
We will process and store your information for any or all of the following purposes;


Whilst on Assignment
The principal purposes for which we collect and store your personal information whilst you are on assignment is to meet our contractual obligations identified within your contract.

During the provision of job seeking activities
The principal purposes for which we collect and store your personal information are to process your job applications, respond to your enquiries, get in touch with you about other possible job opportunities and generally maintain the information you hold with us, together with improving our website. You will be given the opportunity to restrict this use at any time.

To assist with marketing of ATA Recruitment services
In order to ensure that we provide you with the best possible employment opportunity and our client with the best possible candidate, we may also use your data for Marketing purposes.

Occasionally, ATA Recruitment Ltd may contact you by telephone for the purposes of market research, marketing our services (and for telemarketing) where you have consented to us doing so. You are under no obligation to participate in the call.

In addition, we may use an IP address to identify you and to gather broad demographic information about you, which may be used to assist ATA Recruitment in market segmentation activities, to help identify problems with our server and to administer our website.

3.6 What will we do with your information if you are a client/supplier or potential client/supplier
We will process and store your information for any or all of the following purposes;

1. To meet contractual obligations
2. To carry out new business development activities by offering you ATA Recruitment services or products
3. To procure/assess possible services or products that could lead to a contractual engagement.

Contractual Obligations
The principal purposes for which we collect and store your personal information are to meet contractual obligations. In order to provide our services in an effective and efficient manner, we need to ensure that we have the correct communication channels. This is managed by keeping a record of contact positions, email addresses, telephone numbers and business addresses.

New Business Development
Occasionally, ATA Recruitment Ltd may contact you by telephone or email to inform you of our services and capabilities with the intention of developing new business.

In addition, we may use an IP address to identify you and to gather broad demographic information about you, which may be used to assist ATA Recruitment in market segmentation activities.

If you do not object to receiving marketing material at the time the information was collected from you, but subsequently change your mind and no longer wish to receive this information, you can opt out.

3.7 Sharing with 3rd parties
ATA Recruitment Ltd will not sell your personal information to third parties. However, on occasions, it is necessary for us to share personal information with third parties as described below for the purposes referred to above.

3rd Party Data and Purpose
RTC Group ATA Recruitment Ltd is part of the RTC Group Plc family of companies. We may share your information with other group companies to facilitate our commitment to find you the best possible work opportunities and ensure compliance with our processes.
Website analytics providers ATA Recruitment Ltd collates statistics about site traffic, sales and other commercial information. This information is collected through third parties to assist us in improving the services we provide to you. We also use demographic information to tailor the website to the interests of our work seekers and clients, which we share with third parties, again on an aggregate basis only so that they can build up a better picture of our customer base and general consumer trends.
Recruitment and Communications Software ATA Recruitment may require to store or process your data with third parties as is necessary to process your application.
Legal entities ATA Recruitment Ltd may disclose your personal information if necessary to comply with regulations or law or to assist with law enforcement, to enforce the terms under which you are contracted with ATA Recruitment Ltd or to protect our or other third party’s property and other rights.
3rd Party Recruiter/job board You may have accessed our website via a hyperlink from another job board. Your personal details including behavioral patterns, may be shared between ATA Recruitment Ltd and that 3rd party.
Accounting and Business Development Software We may retain contact details of existing / potential clients / suppliers on our accounting software and our Client Relationship Management (CRM) software.
Successor In the event that ATA Recruitment is sold, or some of its assets transferred to a third party, your personal information, as a valuable asset of the company, may also be transferred. However, use of your personal information will remain subject to this Privacy Notice. Similarly, your personal information may be passed on to a successor in interest in the event of a liquidation or administration of ATA Recruitment Ltd.

Where possible all data processors will be within the EEA. If it is a requirement to transfer data outside of the EEA, this will be in accordance with 3.8 Transferring Data outside of the EAA.

3.8 Transferring outside of the European Economic Area (EAA)
ATA Recruitment Ltd will only transfer data outside of the EAA if necessary.

ATA Recruitment Ltd do not currently transfer your Data outside of the European Economic Area. However, should there be a general business requirement to do so, we will record the details in a table below and re-issue this Privacy Notice. Should we be required to pass your information onto a country outside of the European Economic Area on an individual basis, we will seek your permission to do so.

3.9 Consent and Permissions
For the purposes of this Privacy Notice, ATA Recruitment refers to consents and permissions.

The difference between consent and permission can be seen below;
Consent; requires a physical record from yourself.
Permission; can be granted by you and recorded by an ATA Recruitment representative.

By allowing ATA Recruitment to act on your behalf as a recruitment business and recruitment agency, you are giving us permission to do so in accordance with this Privacy Notice.

By submitting your CV, applying for a specific role, or by providing your details, you are giving us permission to retain your details in accordance with this Privacy Notice.

If we have been provided with your details via a 3rd party, we will seek your permission prior to starting the recruitment process. Should this permission not be granted, upon your request, we shall remove your details from our system.

Should you request that we refrain from contacting you in the future, we will, with your permission, retain a skeleton record to which we can record a note of your restrictions.

ATA Recruitment will seek formal consent if data is to be used for the following activities;
1. Processing of EU GDPR defined special categories of personal data
2. Adding your contact details to a marketing list that is different from the uses stated in section 3.5 and 3.6 of this Privacy Notice.

Where we are asking you for special categories of Personal Data we will always tell you why and how the information will be used.

You may withdraw consent or permission at any time by contacting us at optout@ata-recruitment.co.uk.

In the event that you are not already entered into a formal contractual agreement with us, the following permissions will be asked by our recruiters to ensure we understand your wishes correctly.

Would you like us to continue to contact you about possible job opportunities other than the one you are applying? Yes/No
Would you like to receive relevant emails about industry news and career insights? Yes/No

3.10 Profiling and Automated processing
ATA Recruitment utilises automatic profiling to establish whether a candidate meets the minimum requirements of a job application. The exact details of these decisions can be made available upon request.

Automatic profiling is also used when establishing the most applicable industry/sector news or top jobs communicated through our eShot email.

3.11 Retention Period
ATA Recruitment will keep your information for the longer of the period required in order to meet our business, legal or regulatory responsibilities. ATA Recruitment will process, store and dispose of Personal Data in line with our Document Control Procedure, Record Retention Procedure and the RTC Group Information Security Management Manual.

3.12 How will we contact you?
We will contact you in the following circumstances;

Circumstance How Why
If you submit your details to our website in response to a particular job advertisement. Telephone or email in the first instance. To inform you of the status of your application and to further the conversation.
If you submit your details on a speculative basis to our website. Telephone or email in the first instance. To further the conversation and to find out more about how we can help you seek work.
If we receive a referral Telephone, email or social media where appropriate. To find out if you are content to be referred, communicate our Privacy Notice and to confirm permissions if appropriate.
If we find your details on LinkedIn and think that you may be suitable for a current opportunity. Social Media, email and telephone. To find out if you are content to be referred, communicate our Privacy Notice and to confirm permissions if appropriate.
If we receive your CV or contact details through a 3rd Party job board / website Telephone or email in the first instance. To find out if you are content to be contacted, to communicate our Privacy Notice and to confirm permissions if appropriate.
If we believe that we can legitimately assist you with your recruitment requirements Telephone or email in the first instance. To offer our services.
If we believe that we have a need for your products or services. Telephone or email in the first instance To request information about services or products or to engage in contract negotiations.
If we require to contact you for contractual reasons. Telephone or email in the first instance To implement a contractual requirement.

3.13 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that ATA Recruitment Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.15 below.

3.14 Requesting information on the data we hold
ATA Recruitment Ltd, at your request, can confirm what information we hold about you and how it is processed. This is called a Subject Access Request. If ATA Recruitment Ltd does hold personal data about you, you can request copies of the information we hold from the Compliance and Audit Manager on the contact details at the end of this notice.

A Subject Access Request form SAR01 can be requested from our Compliance and Audit Manager. Whilst you do not need to complete the SAR01 form to lodge a Subject Access Request, it will make processing easier.

We will need two different forms of identification to show a facial photograph and address, which can be:

• Passport
• Driving licence
• Birth certificate
• Utility bill (from last 3 months)
• Current vehicle registration document
• Bank statement (from last 3 months)

Your request should be emailed to the Compliance and Audit Manager at info@ata-recruitment.co.uk.

9.4 Complaints and contacts
In the event that you wish to make a complaint about how your personal data is being processed by ATA Recruitment or how your complaint has been handled, you have the right to lodge a complaint directly with the ICO and Data Protection Representative. The details for each of these contacts are:

Supervisory authority contact details Data Protection Representative
Contact name: Information Commissioners Office (ICO) Compliance and Audit Manager
Address line 1: Wycliffe House, The Derby Conference Centre,
Address line 2: Water Ln, London Road
Address line 3: Wilmslow Derby
Address line 4: SK9 5AF DE24 8UX
Email: Doe dpr@ata-recruitment.co.uk
Telephone: 0303 123 1113 01332 861 862
Online: https://ico.org.uk/concerns/handling/