Privacy notice for Franklin Fitch Limited, Franklin Fitch Recruitment Limited and Franklin Fitch Recruitment Contracts Limited, Franklin Fitch Inc and Ovalwood Limited
London: 1 Pickle Mews, London, SW9 0FJ
Cardiff: Brunel House, 2 Fitzalan Rd, Cardiff CF24 0EB
Frankfurt: 7 OG Walter-Kolb-Straße 5- 7, 60594, Frankfurt am Main
Austin: Meridian Plaza, 1601 Rio Grande St, Austin, TX 78701, United States
Our data protection officers:
Algida Gaidyte/ Leonie Schaefer
We act as a controller and we are responsible for the Personal Information we process. This Notice informs you how we protect your Personal Information and informs you about your privacy rights.
The UK General Data Protection Regulation (UK GDPR) (Regulation (EU) 2016/679) is a 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.
The Brexit transition period ended on 31 December 2020 and the UK has now officially left the EU. The UK GDPR has been directly incorporated into UK law sitting alongside the Data Protection Act 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We collect the personal data of the following types of people to allow us to undertake our business;
We collect information about you to carry out our core business and ancillary activities.
In general, our services are related to the provision of recruitment services to clients and we do not process personal data on a large scale, but we will hold certain data in relation to Candidates and individuals affiliated with our clients and suppliers, and this notice sets out the basis on which we hold that data. Depending on the type of personal data in question and the grounds on which we are processing it, should you decline to provide us with such data or ask us to stop processing it, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship. You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time.
We collect some or all of the following personal data (information that can be uniquely identified with you) from time to time:
In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. This applies to both candidates who are searching for a job, and candidates that are applying to work at Franklin Fitch.
Equal opportunities monitoring and other sensitive personal data
We will collect information from a variety of sources, either from you directly or from a third party (for instance your employer, a job site or social media platform you have registered with, or an introducer).
Please note this list is not exhaustive. These may include:
We collect personal data from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data collected in the following situations. Please note this list is not exhaustive:
You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time.
The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we will also use your personal data to provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
We've listed below various ways in which we may use, process and disclose your personal data for recruitment purposes, please note this is not an exhaustive list:
The main reason for using information about clients is to enable us to introduce ourselves to you and to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. We've listed below the various ways in which we use your data in order to facilitate this. Note this is not an exhaustive list:
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
We will only use your information:
We may periodically send you information about our products and services that we think you might like. We might that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements.
Please note that this list is not exhaustive. To:
We collect your data automatically via cookies when you visit our website. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see below. Some of our emails contain a snippet of code, invisible to the naked eye, called a tracking pixel that allows us to understand which of our messages are being opened. If you would prefer that this information was not collected, please disable automatic download of images in your email software or service.
What are cookies and how do we use them?
Advertisement cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs that are similar to jobs that you have previously browsed.
We will share your personal data with various parties, in various ways and for various reasons. This can include:
Website users: Unless you specify otherwise, we will share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive from us is targeted to you.
Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliate. 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 these policies. Please check these policies before you submit any personal data to these websites.
We care about protecting your information. We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary)
Given the niche nature of Franklin Fitch services and market, we have legitimate interests in keeping data for market intelligence purposes. We will attempt to verify the data we hold for you at least every five years.
For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 5 years from the date of receipt by us of that data.
The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
If you wish to request that data we hold about you is amended or deleted, please refer to below, which explains your privacy rights.
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us at email@example.com. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that, where necessary, we will keep a record of your communications to help us resolve any issues which you raise.
Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
Data Subject Access Requests (DSAR): You have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information. At this point we may comply with your request or, additionally do one of the following:
Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data.
Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.
Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.
You may ask to unsubscribe from job alerts at any time. Details of how to do so can be found any email correspondence you receive.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
Transferring your information outside Europe
As part of the services provided to our clients and offered to you, the information you provide to us may be transferred to, processed and stored in countries or international organisations outside of the EEA.
Our client may be based outside of the EEA and we may transfer personal data to our client outside of the EEA. For instance we may transfer Candidate Information to our client outside of the EEA where this is necessary to perform a contract between us and the client and this is in the interests of the Candidate.
Data may be processed by our group companies based outside of the EEA, but we will ensure that any data accessible by our group companies will be subject to a data transfer agreement or binding corporate rules to maintain your rights as a data subject.
If you contact us while you are outside the EEA, your information may be transferred outside the EEA in order to communicate with you.
If we transfer your information outside of the EEA other than in accordance with this clause and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we 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 goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although we will also rely on contractual obligations to which you are subject, legal obligations and consent for specific uses of data.
We will rely on contractual obligations 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.
Our Legitimate Interests
Our legitimate interests in collecting and retaining your personal data is described below:
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 contact details is a fundamental part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs, we require a database of candidate and client personal data. The database will contain 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.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and 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.
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
How to contact us
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following address: Franklin Fitch Limited, 1 Pickle Mews, London, SW9 0FJ firstname.lastname@example.org
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.
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