Valid From: 25 May 2018
Data Protection & Privacy Statement for Christian Bassett Ltd.
1. Who are we?
Christian Bassett Ltd is a global professional, specialist recruitment organisation which focuses on but not exclusive to: C-level Executive, Fashion Design, Finance, HR Store Design, PR & com, VM, Operations & Production, Merchandising, Wholesale and Retail. We provide permanent recruitment services to clients looking to recruit talent for their businesses.
Christian Bassett Ltd. has offices in London, Singapore, Hong Kong and Shanghai,
2. What does this Policy cover?
We at Christian Bassett Ltd. take your personal data seriously. This Policy:
3. What personal data do we collect about you?
We collect the information necessary to be able to find available opportunities and further information needed so our recruiters can assess your eligibility through the different stages of recruitment. This relates to our business which is recruitment but also applications to work for Christian Bassett Ltd. This information includes: your name private and corporate email address, postal address and telephone number; financial information; curriculum vitae; work history; your educational records and training, work performance and right to work; compliance and identity documentation; references and links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Depending on the nature of a role considered for, and also depending upon the applicable jurisdiction, we may need to collect and process sensitive personal data about you which may include information about your health (including details of any sick leave taken during your previous roles), details of any disability, details of any offences you have committed or are alleged to have committed and whether you are a member of any professional or trade associations. Please see section 8 below for the legal basis for such processing.
In addition, as part of our commitment to equality of opportunity and to monitor compliance with our equal opportunity policy, we may ask you to complete an equality monitoring form. Where you are asked to complete an equality monitoring form, information is provided voluntarily and on an anonymous basis for statistical analysis. It is not stored with your other personal records.
4. Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
5. How and why do we use your personal data?
We use your personal data so that we can provide our services to you, including to:
6. How long do we keep your personal data for?
We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
a. our contractual obligations and rights in relation to the information involved;
b. legal obligation(s) under applicable law to retain data for a certain period of time;
c. our legitimate interest where we have carried out a balancing test (see section 8 below);
d. statute of limitations under applicable law(s);
e. (potential) disputes;
f. if you have made a request to have your information deleted; and
g. guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
7. Who do we share your personal data 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, including:
8. What legal basis do we have for using your information?
For candidates, contractors, referees and clients as well as applicants to work for Christian Bassett Ltd. our processing is necessary for our legitimate interests. As a recruitment business and recruitment agency we 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, essential part of this process in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees. In order to support our candidates’ career aspirations and our clients’ resourcing needs we 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 we need to record the personal data of prospective candidates and client contacts.
We carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to and can find out more about the information in these balancing tests by contacting us using the details below.
We will rely on contract if we 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.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal and regulatory obligations, such as disclosure to public authorities, regulators and investigations.
If you are interviewed and submitted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. Such information may be required to perform/qualify for a certain function for which you want to apply based on national laws, which may provide the legal basis to process these data. In cases where there is no legal basis, we will ask for your express consent orally, by email or by an online process for the specific activity we require consent for and record your response. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time (as set out in section 16 below).
9. What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary, object to or withdraw your consent (where applicable) for the processing of your personal data, we may in individual cases not be able to match you with available job opportunities.
10. Do we make automated decisions concerning you?
No, we do not carry out automated profiling as there is human intervention in all our processing of personal data.
11. Do we transfer your data across international borders?
To better match your employee profile with current opportunities, for the purposes of business development, systems development and testing, where required in order for our suppliers to provide a service to us or as necessary in order to perform our services, your personal data may be transferred to clients and partners in countries across international borders as well as our global offices listed at the end of this Policy.
12. Security and storage of your data
Safeguarding personal data and respecting confidentiality of your information is important to Christian Bassett Ltd.
All information you provide to us is stored securely and we take necessary steps, including putting in place appropriate technical and organisational measures, to protect your personal data. While we have security measures in place to protect against the loss, misuse and alteration of personal data under our control we cannot guarantee that loss, misuse or alteration of personal data will not occur.
To find out more about how we safeguard your information as related to transfers please contact us on email@example.com or using the details below.
13. Using our websites – internet-based transfers
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our websites may include links to external websites operated by other organisations which may collect personal data about you when you visit them. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for the privacy practices of any third-party websites. Please check these policies before you submit any personal data to these websites.
15. What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from us using the contact details at the end of this Policy or the data protection regulator in your country.
Rights and what they mean
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
You are entitled to have your information corrected if it’s inaccurate or incomplete.
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
You have the right to object to certain types of processing, including processing for direct marketing or if you no longer want to be contacted with potential opportunities.
You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw any consent to us using your personal data for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
16. Keeping our records accurate and up to date
Christian Bassett Ltd. will review the personal data it processes to ensure that it is up to date and accurate. Your co-operation in helping us to keep your personal data accurate by informing us of any change of name or change of address is an important part of this. If you would like to review or change the details you have supplied us with, you may do so at any time by notifying us in writing.
18. How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another, please just let us know.
19. How can you contact us?
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us here: firstname.lastname@example.org or +44 (0)20 7224 2662 address your query to our global data protection officer Lara Byard at email@example.com.