25th May 2018 V. 1.1.
Who are are
Luxury Assets Ltd. (“us”, “we”) is a recruitment agency with the UK company registration number 08867784.
As an agency we take your privacy seriously and we are committed to protect your data and privacy rights.
This Privacy Notice sets out the basis on which the personal data is collected from you, or that you provide to Luxury Assets Ltd and how it will be stored, processed and safeguarded by us through the service provided.
It explains the rights you have over your data and how we comply with our legal obligations under the new General Data Protection Regulation (GDPR) as of 25th May 2018.
What is Personal Data:
Personal data is classified as any information from which a person can be identified.
Updating this Privacy Notice and Your Personal Data:
From time to time we may update and amend this policy notice and past versions can be obtained. It is important that your personal data is accurate and up to date. Please keep it up to date and inform us of any changes during the time you seek our services. By not providing personal data that has been requested, we may not be able to offer you our recruiting services.
Sensitive Personal Data:
Sensitive personal information, such as about your healthy or criminal records fall into a different category of data. This type of data will only be requested if it is necessary to adhere to legal requirements to ensure you work place is safe or when you are safeguarding minors. If sensitive personal data is supplied without request it will be deleted.
The appointed Data Controller and contact details:
For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Melanie Lamey contactable under melanie@luxuryassets.co.uk and can be reached by writing to the following address:
Luxury Assets Ltd,
43 Berkeley Square,
Mayfair, London W1J 5 FJ, UK,
Telephone contact details: +44 (0) 207 193 8421
This Privacy Notice applies to the personal data obtained from website visits, correspondence or any other communications with CANDIDATES, CLIENTS, REFEREES and WEBSITE USERS and other persons who we may contact.
FOR CANDIDATES:
- The kind of data we collect:
In order to provide you with the most suitable employment opportunities for your needs, we obtain and process your personal information.
|
Type of Data we collect |
Why it is collected |
Legal grounds |
|
Name Address Telephone numbers Username for Skype Photograph Date of Birth Place of Birth
|
To communicate with you To verify you and your information To inform you of suitable roles To set up interviews |
Legitimate Interest Contractual Legal obligation
|
|
CV/ Resume Work history Employers details References Referee details Education details Qualifications Certificates
|
To check your suitability and make an informed choice for any potentially suitable roles |
Legitimate Interest Contractual Legal obligation
|
|
Nationality/ Citizenship Passport/ ID Drivers’ license Immigration status/visa
|
To check your identity, immigration status and legal status to work |
Legitimate Interest Contractual Legal obligation
|
|
Salaries Benefits Pension status
|
To make an informed choice and be able to advise you |
Legitimate Interest |
|
Notes & comments made during the recruitment process
|
To assist you in finding the best suitable role for you |
Legitimate interest Contractual obligation |
|
Email communications Any correspondence SMS messages Skype messages
|
To assist you in finding the best suitable role for you |
Legitimate interest Contractual obligation |
|
Sensitive data on health
|
To examine your suitability for a role and to ensure your health and safety |
Consent Legitimate interest |
|
Sensitive data on security checks |
To examine your suitability for a role |
Consent Legitimate interest |
|
Other necessary applicable personal information |
To carry out our service |
Consent Legitimate interest |
- How is your data being collected:
This data is collected either directly from you through website registration, email, Skype video communication, by phone or SMS or in personal meetings.
Third party data is collected from different sources that include job boards, social media platforms, Google Analytics as well as online searches and information publically available.
- How we use your data and who is it shared with:
This personal data we lawfully request and process assists us to source the best possible employment opportunities for you. The more information we have about your background, experience, skills, requirements and ambitions the more tailored we can make our service to you.
Your personal data will be shared with suitable third parties such as prospective employers and representatives and only as part of our recruitment services. If you do not wish for your personal data to be shared with a particular third party or a group of third parties please let us know.
The purpose of collecting your personal data is required in order to provide you with our recruitment services.
Your personal data will only be used for the purpose it was collected for, unless it may reasonably be needed to use for another reason which is compatible with the original purpose. If the reason to share your personal data does not relate to the original purpose, we will notify you and explain the legal reasons that allow us to do so.
Any third parties are required by law to treat your personal data securely and respectfully for the specified purpose of the recruitment services.
Tax authorities or governments agencies may request us to share specific categories of candidates’ personal data. Some of your personal data may also be shared with lawyers and accountancy services if required.
FOR CLIENTS
- The kind of data we collect:
As a client we require to collect and use information about you, your organization, family, pets, household or staff in order to provide you with recruitment services such as suitable candidates who meet your requirements and fulfil the brief.
|
Type of Data we collect |
Why it is collected |
Legal grounds |
|
Representative or client name Contact details Invoice address |
To communicate with you To present candidates To set up interviews To send an invoice |
Legitimate Interest Contractual Legal obligation
|
|
Company registration details |
To carry out our service |
Contractual Legal obligation
|
|
Details of the role Information about the organization |
To carry out our service |
Legitimate Interest Contractual Legal obligation
|
|
Notes & comments made during the recruitment process
|
To assist you in finding the best suitable candidate |
Legitimate interest Contractual obligation |
|
Email communications Any correspondence SMS messages |
To assist you in finding the best suitable role for you |
Legitimate interest Contractual obligation |
|
Details of placements |
To keep a log of any placements |
Legitimate Interest Contractual Legal obligation
|
|
Other applicable information |
To carry out our service |
Contractual Legitimate Interest
|
- How is your data collected
This data is collected either directly from you, through website registration, email, Skype video communication, by phone or SMS or in personal meetings.
Third party data is collected from different sources (e.g. candidates, etc.), social media platforms, Google Analytics as well as online searches and information publically available.
- How do we use your data and who is it shared with
The purpose of collecting your personal data is required in order to provide you with our recruitment services.
Your personal data will only be used for the purpose it was collected for, unless it may reasonably be needed to use for another reason which is compatible with the original purpose. If the reason to share your personal data does not relate to the original purpose, we will notify you and explain the legal reasons that allow us to do so.
Any third parties are required by law to treat your personal data securely and respectfully for the specified purpose of the recruitment services.
Some of your personal data may also be shared with lawyers and accountancy services if required.
FOR REFEREES
- The kind of data we collect:
We obtain some basic contact details in order to make a suitable employment opportunity to potential candidates.
|
Type of Data we collect |
Why it is collected |
Legal grounds |
|
Name of referee Contact details
|
To communicate with you To obtain a reference
|
Legitimate Interest
|
|
Notes & comments made to obtain the reference
|
To obtain a reference
|
Legitimate interest |
|
Email communications Any correspondence SMS messages |
To carry out our services |
Legitimate interest Contractual obligation |
- How is your data collected
The contact details are supplied on our request from candidates and are either provided to us as part of references supplied or in the format of communications from candidates.
- How do we use your data and who is it shared with
The personal data of referees assist us in finding the most suitable candidates for our clients. We seek the verification of candidate’s detail and their skills.
FOR WEBSITE USERS:
- The kind of data we collect:
To help us improve your experience we collect a limited amount of data from our website. This includes details on how you use our website, the frequency and the times when our website is most used.
- How is your data collected
Data is collected via cookies when you visit our website depending on the cookie settings of your browser. Our website only uses the Google Analytics cookie. This is for anonymous tracking and the data is used solely for website improvements. You can disable cookies in your browser if you wish to avoid this.
- How do we use your data and who is it shared with
We may use the data from our website to better all our communications and services with you. Unless you chose otherwise, we may share your data with providers of analytical services.
FOR CANDIDATES, CLIENTS, REFEREES AND WEBSITE VISITORS:
HOW WE STORE YOUR PERSONAL DATA
Security
We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Where We store your personal data
Your personal data is stored in a system supplied by a data processing company, located on secure servers within the EEA (European Economic Area) as well as Norway, Lichtenstein, Switzerland and Iceland. These countries are subject to strict protection and adequate safeguarding measures put in place by the European Commission.
How long we keep your personal data
If we not had any meaningful contact for three years we will delete your personal data from our database unless we are required by law or other regulations to preserve it (there may be obligations to tax authorities to do so in which case it could be as long as seven years).
YOUR RIGHTS
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data we hold about you
- require Us to correct any mistakes in your information which we hold
- object at any time to processing of personal data concerning you
- require the erasure or restriction of personal data concerning you
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- otherwise restrict our processing of your personal data in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- contact us using our Contact details below
- let Us have enough information to identify you,
- let Us have proof of your identity and address, and
- let Us know the information to which your request relates.
How to complain
We hope that we can resolve any query or concern you raise about Our use of your information. If not, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone:0303 123 1113.
Contact
All questions, comments and requests regarding this Privacy Notice should be addressed to Melanie Lamey, email address: melanie@luxuryassets.co.uk