Legal

Bateman Fox Limited (”Bateman Fox”) are committed to protecting and respecting your privacy.

This notice sets out the basis on which any personal data Bateman Fox collect from you, or that you provide to us, will be processed by us.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) (“GDPR”) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

Your rights under GDPR are set out in this notice and apply from 25 May 2018.

Please read the following carefully to understand our views and practices regarding your personal data and how Bateman Fox will treat it.

For the purposes of data protection legislation in force from time to time the Data Controller is Bateman Fox Limited of Worthy House, 14 Winchester Road, Basingstoke, Hampshire, United Kingdom, RG21 8UQ

Our nominated Data Protection Officer is Jamie Little

Who Bateman Fox are and what we do
Bateman Fox are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). Bateman Fox collect the personal data of the following types of people to allow us to undertake our business:
• Prospective and placed candidates for permanent or temporary roles
• Prospective and live clients
• Supplier contacts to support our services
• Our employees, consultants, temporary workers.

Bateman Fox collect information about you to carry out our core business and ancillary activities.

Information you give to us or we collect about you
This is information about you that you give us by visiting our website or by corresponding with us by phone, e-mail, SMS or otherwise. It includes information you provide when you:
• Register as a candidate to enter our database
• Register a new vacancy
• Subscribe to receive company news or our jobs-by-email
• Apply for jobs
• Request a job to be emailed to you
• Refer colleagues or friends as part of our referral program
• Enter a competition or take part in a survey
• Register to attend an event Bateman Fox organise
• Participate via social media functions on our Website

The information you give us or Bateman Fox collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom or Europe, curriculum vitae (or career profile) and photograph and data that may be held on your professional profile available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

Bateman Fox may need to collect and process sensitive personal data about you. The GDPR defines sensitive personal data as data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Information Bateman Fox collect about you when you visit our Website
When you visit our Website Bateman Fox will automatically collect the following information:

Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, operating system and platform.

Information about your visit, including the full Uniform Resource Locators (URL) of each page visited, clickstream to and through our Website including date and time, jobs visited and searched for, download errors, length of visits to pages, and any information submitted through forms.

Information Bateman Fox obtain from other sources
This is information Bateman Fox obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case Bateman Fox will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact Bateman Fox hold personal data about you.

Purposes of the processing and the legal basis for the processing
Bateman Fox use information held about you in the following ways:
To carry out our obligations arising from any contracts Bateman Fox intend to enter into or have entered into between you and Bateman Fox to provide you with the information and services that you request from us or Bateman Fox think will be of interest to you because it is relevant to your career or to your organisation.

To provide you with information about other services or jobs that Bateman Fox offer that are similar to those that you have already been provided with or enquired about.

The core service Bateman Fox offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent recruitment. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.

Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although Bateman Fox will also rely on contract, legal obligation and consent for specific uses of data.

Bateman Fox will rely on any existing contract if Bateman Fox are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

Bateman Fox will rely on legal obligation if Bateman Fox are legally required to hold information on to you to fulfil our legal obligations.
Bateman Fox will rely on your consent for particular uses of your data and you will be asked for your express consent, if legally required e.g. when we are processing sensitive personal data or when gaining your permission to introduce you to a client (if you are a candidate).

Our Legitimate Interest
Our legitimate interest in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency Bateman Fox introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental and essential part of this process.

In order to support our candidates’ career aspirations and our clients’ resourcing needs Bateman Fox require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

To maintain, expand and develop our business Bateman Fox need to record the personal data of prospective candidates and client contacts.

Consent
Should Bateman Fox want or need to rely on consent to lawfully process your data Bateman Fox will request your consent orally, by email, by SMS or by completing an online process for the specific activity (e.g. when registering a vacancy or as a candidate or when you apply for a job) when Bateman Fox will require your consent for and to record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Other Uses Bateman Fox will make of your data:
• Use of our Website
• to notify you about changes to our service
• to ensure that content from our Website is presented in the most effective manner for you and for your computer.

Bateman Fox will use this information:
• to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• to improve our Website to ensure that content is presented in the most effective manner for you and for your computer
• to allow you to participate in any interactive features of our service, when you choose to do so;
• as part of our efforts to keep our Website safe and secure
• to measure or understand the effectiveness of the information, news and job advertising Bateman Fox serve to you and others, and to deliver relevant information, news and job advertising to you
• to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.

Bateman Fox do not undertake automated decision making or profiling. Bateman Fox do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.

Disclosure of your information inside and outside of the EEA

Bateman Fox will share your personal information with:

Selected third parties including:
• clients (or a nominated party acting on behalf of our clients) for the purpose of introducing candidates to them
• candidates for the purpose of discussing job opportunities to them, the arranging of interviews and engagements
• clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract Bateman Fox enter into with them or you
• subcontractors including email marketing specialists, event organisers, payment and other financial service providers
• Bateman Fox may make use of the personal data Bateman Fox have collected from you to enable us to display our adverts to the correct targeted audience
• analytics and search engine providers that assist us in the improvement and optimisation of our Website
• credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

Bateman Fox will disclose your personal information to third parties:
• In the event that Bateman Fox sell or buy any business or assets, in which case Bateman Fox will disclose your personal data to the prospective seller or buyer of such business or assets
• If Bateman Fox or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
• If Bateman Fox are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of use and other agreements; or to protect the rights, property, or safety of Bateman Fox, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The lawful basis for the third-party processing will include:

• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs
• satisfaction of their contractual obligations to us as our data processor
• for the purpose of a contract in place or in contemplation
• to fulfil their legal obligations.

Where Bateman Fox store and process your personal data
The data that Bateman Fox collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Bateman Fox will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

Unfortunately, the transmission of information via the internet is not completely secure. Although Bateman Fox will do our best to protect your personal data, Bateman Fox cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once Bateman Fox have received your information, Bateman Fox will use strict procedures and security features to try to prevent unauthorised access.

Retention of your data
Bateman Fox will retain your personal data for as long as necessary in order to provide the recruitment service to you and for the purposes of satisfying any legal, accounting, regulatory or reporting requirements

Bateman Fox do the following to try to ensure our data is accurate:
• prior to making an introduction Bateman Fox check that Bateman Fox have accurate information about you
• Bateman Fox keep in touch with you so you can let us know of changes to your personal data
• Bateman Fox make use of external websites (e.g. LinkedIn) to verify the information about you.

The criteria Bateman Fox use to determine whether Bateman Fox should retain your personal data includes:
• the nature of the personal data
• its perceived accuracy
• our legal obligations
• whether Bateman Fox have been active with you as part of our general recruitment service (e.g. discussing roles with you, arranging interviews or placing you in a new role)
• our recruitment expertise and knowledge of the industry by country, sector and job role
Bateman Fox may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our systems. Bateman Fox may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that Bateman Fox do not re-enter your personal data on to our database, unless requested to do so.

For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

Your rights
You have the right to ask us not to process your personal data for marketing purposes. Bateman Fox will usually inform you (before collecting your data) if Bateman Fox intend to use your data for such purposes or if Bateman Fox intend to disclose your information to any third party for such purposes and Bateman Fox will collect express consent from you if legally required prior to using your personal data for marketing purposes

The GDPR provides you with the following rights
To:
• Request correction of the personal information that Bateman Fox hold about you. This enables you to have any incomplete or inaccurate information Bateman Fox hold about you corrected
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below)
• Object to processing of your personal information where Bateman Fox 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. You also have the right to object where Bateman Fox are processing your personal information for direct marketing purposes
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
• Request the transfer of your personal information to another party in certain formats, if practicable
• Withdraw your consent to the collection, processing and transfer of your personal data (“Opt-out”). You have the right to Opt-out at any time. Once we have received notification that you have Opted-out we will no longer process your personal data for the purpose of providing you with the Recruitment Service, unless we have another legitimate basis for doing so in law
• To Opt-out or withdraw your consent please email info@batemanfox.com. To make any other changes to how we process your personal data please email info@batemanfox.com supplying your name and contact details
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted at: https://ico.org.uk/concerns/

Access to information:
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. Bateman Fox also encourage you to contact us to ensure your data is accurate and complete. Please note that you will not usually need to pay a fee to access your personal data or to exercise any other rights. However, Bateman Fox may charge a reasonable fee if your access request for access is excessive. In such circumstances, Bateman Fox reserve the right to refuse to comply with the request
A subject access request should be submitted by email to info@batemanfox.com