Privacy Policy

This Privacy Policy sets out the basis on which TritonExec will process personal information provided to us, this information is referred to as ‘personal data’.

We take our obligations in respect of the privacy of personal data seriously and we will only process personal information as detailed in this notice, unless we inform you otherwise. In order to ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information we hold about you.

For the purposes of this Privacy Notice, our commercial activities and services for individuals and businesses are referred to as ‘Recruitment Services’, and our actual or potential hiring customers are referred to as ‘Clients’.

If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us.  Please refer to Section 4 ’Your rights ‘, in respect of data that we already hold, or which we receive from third parties.

SECTION 1

This section applies to individuals wishing to use or using our Recruitment Services or looking for a role to work with us (‘a Candidate’).

The personal data we collect or receive includes the following as applicable:

• Name
• Address
• Email and other contact details
• Date of birth
• Remuneration details
• Work history (including information relating to placements through TritonExec)
• Educational history, qualifications & skills
• Visa and other right to work or identity information
• Passport
• National insurance details
• Contact details of referees
• Information contained in references and pre-employment checks from third parties
• References and links to your professional profiles available in the public domain such as LinkedIn, Twitter or corporate website
• Other sensitive personal information such as health records or criminal record checks (see ‘Sensitive Personal Data’ section below)
• Your marketing preferences

We may obtain your personal data from the following sources (please note that this list is not exhaustive):

• Directly from you (e.g. a Curriculum Vitae, application or registering an interest with us)
• By reference or word or mouth, for instance you may have been recommended by a friend, former employer or colleague
• Job boards that you have registered your details on
• Online Curriculum vitae libraries
• The public domain e.g. corporate websites
• Social Media
• Conversations on the telephone or video conferencing (which may be recorded)
• Notes following a conversation or meeting
• Our website contact forms and software applications
• Where you are a Candidate and we have obtained your personal data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you.

How do we use your personal data?

We use your personal data so that we can provide our Recruitment Services to you, including:

• Managing and maintaining our relationship with you to perform administration of operational functions
• Provide you with recruitment services, which may include career guidance and notifying you of potential roles or opportunities
• Assessing and reviewing your suitability for job roles
• Introducing and/or supplying you to actual or potential Clients
• Managing and maintaining our relationship with you to perform administration of operational functions
• Engaging you for a role with us or with our Clients
• Conduct market research and satisfaction surveys
• Collating market or sector specific information and providing the same to our Clients
• Responding to your queries
• Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services
• Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
• Advise you of news, reports, industry updates, events, services, promotions and any other information that we feel may be of interest to you
• Retaining a record of our dealings
• Establishing quality, training and compliance with our obligations and best practice
• For the purposes of backing up information on our computer systems
• Notify you of any changes to our Recruitment Services or this Privacy Policy

 

What if we obtain your personal data from a third party?

Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.

 

Where information from third party sources is of no use to us, or where you have notified us that you do not want us to provide you with services, we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Recruitment Services, any processing will be in accordance with this Privacy Policy. You do have the right to object to processing, please see Section 4 ‘Your rights’.

Automated decisions

Our processing of data as detailed above will always be subject to human review and involvement.

SECTION 2

This section applies where you are an individual working for a third party with whom we have dealings. For example, a Client.

We may collect your personal data in the course of our dealings and this may include the following:

• Your contact information, which may include your full name, job role, contact telephone number and email
• Your statements and opinions about candidates and/or other personnel e.g. a reference
• Information relating to our relationship with you or the party for whom you work including records of any meetings or discussions
• Your marketing preferences

We may obtain your personal data from the following sources (please note that this list is not exhaustive):

• Directly from you, including where you have provided us with your contact details or other information for the purposes of using our Recruitment Services
• Colleagues or other representatives of the organisation you represent
• Candidates
• Marketing databases
• Social media
• The public domain
• Conversations, with you or others, on the telephone or video conferencing (which may be recorded) or in meetings
• Notes following a conversation, with you or others, or meetings you attend

How we will use your personal data:

We will process your personal data in the context of our dealings with the third party for whom you work and as part of our Recruitment Services. Processing may include:

• Manage and maintain our business relationship
• Using the data to communicate with you
• Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services
• Actions necessary to further any obligation on us pursuant to a contract between ourselves and the third party you work for
• Collating market or sector specific information
• Carrying out market research, marketing analysis and satisfaction surveys
• Advising you of new, industry updates, events and services
• Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers
• Retaining records of our dealings with you and the organisation whom you represent
• Establishing quality, training and compliance with our obligations and best practice

SECTION 3

This section applies to all personal data.

Sensitive Personal Data

Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, criminal record or information relating to your health.

We request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our Recruitment Services. This will be for one or more of the following reasons:

• You have explicitly consented to the processing
• For the purpose of our assessment of your suitability for job roles or working capacity
• Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
• To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims

Who your data is shared with

Your personal data may be shared with certain third parties who will be subject to contractual obligations of confidentiality and compliance with relevant laws.  Those with whom we share your personal data with may include:

Our employees

• Individuals, hirers and other third parties necessary for the provision of our Recruitment Services
• Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
• Parties who process data on our behalf, which may include
  • outsourced administration providers
  • IT software and service companies
  • storage service providers including cloud
  • background screening providers
  • Legal and professional advisers
  • Insurers
  • Event organisers and coordinators

Why we process your personal data

To provide Recruitment Services, the exchange of personal data of our candidates and clients is fundamental to how our business operates.  The exchange of personal data is required to be able to find potential candidates, assess a candidate’s suitability for roles and to contact clients in order to fulfil their hiring requirements. In order to support these functions, we require a database of both candidate and client personal data containing historical information as well as current resourcing needs. To maintain and develop our business we also need to record the personal data of prospective candidates and client contacts.

1 Legitimate interest

In providing our Recruitment Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include using your personal data:

• To contact you regarding our Recruitment Services
• To assess suitability of Candidates and roles, for example, referencing or other feedback
• To collate market information or trends including providing analysis to potential or actual Clients
• As otherwise necessary to provide our Recruitment Services and/or to meet our obligations towards either the party whom you represent, or other Clients or suppliers
• To personalise your experience and our offering, whether via our website or otherwise

Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:

• establishing compliance with contractual obligations with Clients or suppliers
• addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
• protecting our reputation
• maintaining a backup of our systems, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
• evaluating quality and compliance including compliance with this Privacy Policy
• determining staff training and system requirements
• For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.

2 Consent

We may process your personal and sensitive personal data on the basis that you have consented to us doing so for a specific purpose or reason.  Where we seek consent, this may be done orally, by email or by an online process, please note that your response will be recorded.  Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

You may withdraw your consent to our processing of your personal information for a particular purpose at any time. However, we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations.

3 Performance of a contract

In order to provide our Recruitment Services, we may enter into a contract with you and/or a third party. A contract will contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those obligations.

4 Compliance with legal obligations (regulatory and statutory)

We must comply with a number of statutory provisions when providing our Recruitment Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things requires us to:

• Verify your identity
• Assess your suitability for an external job role
• Maintain records for specific periods

We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities such as HMRC or the Information Commissioner’s Office.

If you do not wish to provide us with necessary data

There may be circumstances where we require you to provide data which is necessary in order for us to meet statutory or contractual obligations, or perform our Recruitment Services. If you do not wish to provide us with information, we request then please notify us. However, please be aware that as a result we may be unable to provide you or the party who you represent with a Recruitment Service, and in some cases, may result in a breach of the contract we have with you or a third party you represent.

Transfer of data to other jurisdictions

In the course of the provision of our Recruitment Services we may transfer data to countries or international organisations outside of the EEA. This may, for example, be to Clients or Candidates, or third parties who provide support services to us. It is our policy to take steps to identify risks so far as is reasonably practicable and ensure that appropriate safeguards are in place to protect personal data.

Data Security and Confidentiality

It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties. We will ensure that appropriate measures are taken against unlawful and unauthorised processing of personal data and against the accidental loss or damage to personal data.

 

Whilst we have appropriate technical and organisational measures in place to protect your personal data against the loss, misuse and alteration of personal data under our control we cannot guaranteed that loss, misuse or alteration of personal data will not occur.

Retaining your data

We only retain your information for as long as necessary for us to use your information as described above or to comply with our legal obligations.  When your personal data is deleted it is erased securely.

However please be advised that we may retain some of your information after you cease to use our services, for instance:

• if it is necessary for us to comply with legal or contractual obligations
• it is required to defend TritonExec in the event of a potential dispute
• for legitimate business interests.

If, however you have made a request for your information to be deleted, this will be processed in line with your request and not by our standard retention period. Please see Section 4 ‘Your Rights’ below.

Cookies

We use cookies on our website, which collect your personal data when you browse. You can find out about the cookies we use by viewing our Cookie Policy.

Changes to this Privacy Policy

This Privacy Policy is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice. Where an update is relevant to our processing of your data, we shall notify you.

SECTION 4

Your Rights

By law you have a number of rights when it comes to personal data, they include:

• The right to be informed
• The right of access
• The right of rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to lodge a complaint
• Rights to automated decision-making including profiling

Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third-party source.

 

If you have any questions concerning your rights or should you wish to exercise any of these rights please contact the Operations Director, whose contact details are listed below.

Complaints

If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to TritonExec’s Operations Director. This does not affect your right to make a complaint to the Information Commissioner’s Office.

TRITONEXEC CONTACT

Operations Director

Sarah Banting

Email: sbanting@tritonexec.com

DD: 0203 589 2764