Aspire People’s Privacy Notice

The Company is a recruitment business which provides work-finding services to its clients and workseekers.

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 this privacy statement. At all times we will comply

with current data protection laws.

Contents

1. Collection and use of personal data

a. Purpose of processing and legal basis

b. Legitimate interest

c. Statutory/contractual requirement

d. Recipients of data

2. Information to be provided when data is not collected directly from the data subject

a. Categories of data

b. Sources of data

3. Overseas transfers

4. Data retention

5. Your rights

6. Automated decision making

7. Cookies

8. Login files

9. Links to external sites

10. Sale of the business

11. Data security

12. Changes to this privacy statement

13. Complaints or queries

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1. Collection and use of personal data

a. Purpose of processing and legal basis

The Company will collect 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.

If you have opted-in we may also send you marketing information and news via email/ text. You can opt-out

from receiving these at any time by clicking “unsubscribe” when you receive these communications from us or

by contacting us to that effect by other means.

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.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our workfinding

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 our Child Protection Policy

b. 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:

• Managing our database and keeping work-seeker records up to date;

• Providing work-finding services to you and our clients;

• Contacting you to seek your consent where we need it;

• Giving you information about similar products or services that you have used from us recently;

• To fulfil our Child Protection Policy

c. Statutory/contractual requirement

The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the

Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax

legislation, and in some circumstances safeguarding requirements.) Our clients may also require this personal

data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we

need to collect we may not be able to continue to provide work-finding services to you.

d. Recipient/s of data

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

• Clients (whom we may introduce or supply you to for eg. Schools, Nurseries, Colleges, Universities and/or Local

Authorities)

• Former employers whom we may seek references from

• Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to

• The Recruitment and Employment Confederation (REC)

• Disclosure and Barring Service (DBS) and DBS check providers

• Local Authority Designated Officers (LADO)

• Her Majesty’s Police Service, Her Majesty’s Revenue and Customs (HMRC)

• Employment Agencies Standards Inspectorate (EASI)

• National College for Teaching and Leadership (NCTL)

• Other recruitment agencies in the supply chain

• Our Insurers who also ensure work-seekers on placement

• Social networks

• Our IT and CRM Providers

• Trade Unions

• Any organisation that an individual work-seeker asks to share their specific information with.

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2. Information to be provided when data collected not from the data subject

Categories of data: The Company has/may have collected the following personal data on you:

Personal data:

• Name, address, mobile number, home phone number, email

• Previous names, address history

• Date of birth

• National insurance number

• Nationality

• Protected characteristics information

• CV

• Reference details and/or previous work references

• Next of Kin details

• Time spent overseas in the last 4 years

• Sensitive personal data:

• Health information including whether you have a disability

• Criminal conviction

• Information relating to disqualification by associations

• Any previous Orders and/or Restrictions relating to working with vulnerable adults and children

• Sources of the personal data: The Company sources/sourced your personal data/sensitive personal data

• A former employer

• A colleague who referred your details to us

• Job boards and/or CV databases to which you supplied the information

• A referee whose details you previously provided to us

• Software providers who we use to support our services

• Cookies listed in section 7

• The Recruitment and Employment Confederation (REC)

• Disclosure and Barring Service (DBS) and DBS check providers

• Local Authority Designated Officers (LADO)

• Her Majesty’s Police Service, Her Majesty’s Revenue and Customs (HMRC)

• Employment Agencies Standards Inspectorate (EASI)

• National College for Teaching and Leadership (NCTL)

• Other recruitment agencies in the supply chain

This information did/does/will not come from a publicly accessible source.

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3. Overseas Transfers [Optional]

The Company will not transfer the information you provide to us to countries outside the UK.

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4. Data retention

The Company will retain your personal data only for 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. For example, 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 pension’s auto-enrolment records for as long

as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is

currently 3 to 6 years. Where the Company has obtained your consent to process your personal and sensitive personal data, we will

do so in line with our retention policy (a copy of which is attached and/or available on request). 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 and sensitive personal data.

Any information relating to Child Protection, we will retain on file indefinitely.

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5. 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 either Aspire People’s Ops and HR Director

(DPO) or Aspire People’s Compliance Manager (DSO) on 0121 314 3606 or at compliance@aspirepeople.co.uk.

Please note that if you withdraw your consent to further processing that does not affect any processing done

prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal or official reasons.

Where this is the case, we will tell you and we will restrict the data to only what is necessary for 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.

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6. Cookies

We may obtain data about you from cookies. These are are small text files that are placed on your computer

by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well

as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.

The table below explains the cookies we use and why.

Most web browsers allow some control of most cookies through the browser settings.

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7. Log Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad

demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

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8. Links to external websites

The Company’s website may contain links to other external websites. Please be aware that the Company is not

responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the

privacy statements of each and every website that collects personally identifiable information. This privacy

statement applies solely to information collected by the Company’s website.

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9. Sale of business

If the Company’s business is sold or integrated with another business your details may be disclosed to our

advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the

business.

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10. Data Security

The Company takes every precaution to protect our users’ information. Please note that Aspire People is a

holder of the Cyber Essentials Certificate of Cyber Security, meaning that is has been externally verified and

had confirmation that the your personal and sensitive data is secure on our servers.

Only employees who need the information to perform a specific job (for example, consultants, our accounts

clerk or a marketing assistant) are granted access to your information.

The Company uses all reasonable efforts to safeguard your personal information. However, you should be

aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot

guarantee the security or integrity of any personal information which is transferred from you or to you via email/

the Internet. If you share a device with others we recommend that you do not select the “remember my details” function

when that option is offered. If you have any questions about the security at our website, you can email compliance@aspirepeople.co.uk

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11. Changes to this privacy statement

We will update this privacy statement from time to time. We will post any changes on the statement with

revision dates. If we make any material changes, we will notify you.

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12. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Aspire

People’s Compliance Manager or Aspire People’s Ops and HR Director on compliance@aspirepeople.co.uk or

on 0121 314 3606. 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.