INTRODUCTION
Welcome to Marshall Harmony Limited privacy policy.
Marshall Harmony Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how Marshall Harmony Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when or when you sign up to our services via other means (this could be by way of email, jobs boards (e.g. Reed, CV Library etc.) or social media websites such as LinkedIn.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
CONTROLLER
Marshall Harmony Limited is the controller and responsible for your personal data (collectively referred to as "Marshall Harmony", "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Marshall Harmony Limited
Email address: admin@marshallharmony.co.uk
Company Number: 10981348
VAT Number:304984883
C/O Baillie Accountants, 28 High Street, Ironbridge, TF8 7AD
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, photographs (if supplied), marital status, title, date of birth and gender.
• Contact Data includes postal address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Employment Profile Data includes your CV, covering letters, right to work information (e.g. visa, passport, birth certificate or NI number), employment references obtained from third parties and another other employment related data you may provide to us during our delivery of our recruitment services.
• Usage Data includes information about how you use our website.
• Communications Data includes your preferences in receiving communication about potential employment opportunities.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature, or you Contact Data to calculate where our highest concentration of clients are located. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not specifically ask for Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, when arranging for an interview with your potential employer it may be necessary to ask you for details of any disabilities or health issues which you have so that we or your potential employer can make reasonable adjustments to the interview environment for you (e.g. wheelchair access).
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform our recruitment services for you). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Employment Profile Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our recruitment services;
• request for employment opportunities to be sent to you; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data
about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar
technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
(a) analytics providers such as Google based outside the EU;
(b) Feedback from those companies with which you apply for employment through us.
(c) Social and professional networking sites such as LinkedIn, Facebook, Twitter, Instagram, GitHub, Stackoverflow and
many others
(d) Job Boards such as Reed, Total Jobs, Monster, Indeed.co.uk, CV Library and many others.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the “contract” for recruitment services we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new client. |
(a) Identity |
Performance of a contract with you |
|
To contact you about employment vacancies which |
(a) Identity |
(a) Performance of a contract with you |
|
we believe you might be interested in. |
(b) Necessary for our legitimate interests (to contact you about jobs which you might not have asked for information about but we think may be of interest to you). |
|
|
To manage our relationship with you which will include: (b) Asking you if you still want to stay on our mailing list. |
(a) Identity |
(a) Performance of a contract with you. (c) Necessary for our legitimate interests (to keep our records updated to ensure we are only contacting those people who want to hear from us). |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
|
To use data analytics to improve our website, services, customer relationships and experiences. |
(a) Technical |
Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy). |
|
To arrange, on your behalf, appropriate adjustments to your interview environment to accommodate any disabilities or health related issues that you may have. |
(a) Identity |
We take your voluntary supply of this data as your consent to use such data for this purpose only. |
COMMUNICATIONS FROM US
We may use your Identity, Contact and Employment Profile Data to form a view on potential roles we think might be of interestto you.
You will receive communications from us if you have requested information from us, applied for a vacancy through us and you have not opted out of receiving further communications.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you communications at any time by following the opt-out links on any emails message sent to you.
Where you opt out of receiving these communications, this will not apply to personal data provided to us as a result of your use of our recruitment services.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy on our website.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
• Internal Third Parties such as our employees.
• External Third Parties such as the employer of the role for which you are applying, your chosen reference provider and any other party who is necessary for us to involve in the recruitment process such as our provider of applicant tracking systems software – Vincere.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
However, generally we will retain your personal data for a period of 24 months from the date your details are registered on our Applicant Tracking System, Vincere.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
9.1 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
9.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
9.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however,
that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
9.4 Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
9.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend
legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to
use it.
9.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you
have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right
only applies to automated information which you initially provided consent for us to use or where we used the
information to perform a contract with you.
9.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this
will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw
your consent, we may not be able to provide certain products or services to you. We will advise you if this is the
case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.