The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.

1. Collection and use of personal data

A. Purpose of processing and legal basis

The Company has collected your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.

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.

The legal bases we rely upon to offer these services to you are:

• Your consent
• Where we have a legitimate interest
• To comply with a legal obligation that we have
• To fulfil a contractual obligation that we have with you
• To fulfil a contractual obligation, we have with our customers

B. Categories of Data

The Company has collected the following personal data on you:

Personal data:

Name; age/date of birth; sex/gender; marital status; contact details; education details; employment history; emergency contacts; referee details; immigration status (whether you need a work permit); nationality/citizenship/place of birth; a copy of your driving licence and/or passport/identity card; diversity information including racial or ethnic origin, details about your current remuneration, benefits or tax arrangements; information on your interests and needs regarding future employment, both collected directly and inferred; information that you choose to tell us; extra information that we find from other third party sources such as job sites.

Sensitive personal data:

Health-related information, of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for.

C. Legitimate Interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.  Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• For our candidates, we provide work finding services within a specialist area of construction, engineering and energy generation. We process your data in response to a job application, your posting of data on job boards or professional networking sites or a recommendation to the Company. in order to provide this service, we will assess your CV and match it to vacancies, secure your placement and manage your assignment. We will also need to provide you with reports on the work we are undertaking on your behalf, advise you of relevant services and products, provide you with information about general trends in the world of work in our specialist area and seek your feedback on our services.
• For our customers, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as the supply of candidates for vacancies, keeping you up to date with changes in the job market and providing you with any recruitment activity or industry specific reports.
• If you supply services to the Company, we need contact details of individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide

D. Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

• We will share your information with prospective employers to increase your chances of securing the job you want. In addition, will we share with the following recipients:

Former or prospective new employers, in-house recruiters, potential applicants to your vacancy, referees, Company subsidiaries, the REC and other trade bodies, local tax, regulatory or law enforcement authorities,  our banking providers and third parties that may audit our company processes. Our Payroll service, umbrella/management companies, our insurers and IT/CRM provider, approved 3^rd party recruitment technology providers who help with CV formatting, data storage and vacancy marketing services.

2. Overseas Transfers

The Company may transfer only the information you provide to us to countries outside the European Economic Area (“EEA”) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

3. Data Retention

 The Company will retain your personal data for a minimum of 5 years, as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.

Where the Company has obtained your consent to process your personal and sensitive personal data/specify which personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your [personal data and sensitive personal data].

4. Your rights

Please be aware that you have the following data protection rights:

• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Curtis Thompson at GDPR@turnerlovell.com.

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

5. Automated decision-making [Optional]

We do not currently use  automated technologies such as expert systems or machine learning in our recruitment process. If we do, we will ensure that you consent to profiling or if there is no consent, your selection will be done manually by a suitable person.

6. Source of the personal data

The Company sourced your personal data/sensitive personal data by the following means:

• Directly from you, via a CV or email, from our website, from one of our social media channels. We receive your data from job sites, professional network sites such as LinkedIn or Xing, from customers, from references and from other agencies or recruitment partners working for our customers.

7. Visitors to our website

We use Google Analytics and cookies to gather general information about visitors to our websites in order to better understand how our websites are used. We may share this general information with trusted third parties so they too may understand how our websites are used. You may use your browser settings to opt-out of the use of cookies.

If we hold an email address for you, we may occasionally use cookies to gather information about your personal use of our websites. This is in order to provide you with a tailored service.  You may find further information about our use of cookies by emailing us at GDPR@turnerlovell.com

If you contact us through our website to submit an application, submit your CV, ask a question or download a report or document, we will ask you to agree that you accept the terms of this privacy policy and thereby give consent to the processing of your personal information and future contact.

Our websites may contain links to external websites operated by other organisations. Those organisations may collect personal information from visitors to their site. The Company cannot guarantee the content or privacy practices of any external websites and does not accept responsibility for those websites.

8. Security

The Company is committed to protecting the security of your personal information. We use a variety of measures, including but not limited to, firewalls and SSL encryption in order to protect your personal information from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification or alteration
• Unlawful destruction or accidental loss

9. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it or to view our data protection policy please contact Curtis Thompson at GDPR@turnerlovell.com

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.