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: Suite 6, 9th Floor, Brunel House, 2 Fitzalan Road, Cardiff, CF24 0EB
Frankfurt: 7 OG Walter-Kolb-Straße 5- 7, 60594, Frankfurt am Main
Austin: WeWork 6th Floor, c/o Franklin Fitch Inc, 316 West 12th Street Austin, TX 78701
Our data protection officers:
Alison Moss/ Leonie Schaefer
Whose data do we collect?
What data do we collect?
How do we collect your data?
How do we use your data?
Who do we share your data with?
How do we safeguard & store your data?
How long do we store your data for?
How to amend or withdraw consent
How do we store and transfer your data internationally?
Purposes of the processing and the legal basis for the processing
How to contact us
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;
You are a customer or supplier of ours (or are interested in becoming so)
You use our products or services as a candidate or prospective candidate whose data we process for proposed roles with our clients or prospective clients
You are an individual affiliated with a corporate contractor candidate, or an individual or employee associated or affiliated with our client or supplier
Where a given role with our client is to be filled by a limited company or other corporate contractor we may process data relating to that company’s directors or shareholders
You work for a customer or a supplier of ours, or for someone who uses our products or services
You are someone (or you work for someone) to whom we want to advertise or market our goods or services
You have expressed an interest in working for us
You visit our website
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.
Your name, your work background, work history. This information may include name, address, telephone number, email address, CV, work history, educational qualifications, age, gender, income, certifications, marital status, visa status, current employment and compensation package, previous employment and compensation package as well as personal references and relevant social media information e.g. LinkedIn
A record of any correspondence or communication between you and us
Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health, diversity information or details of any criminal convictions. For certain ‘special categories’ of sensitive personal data including data relating to health and ethnic background which we may process from time to time, we will process this data on the basis of your consent
Marketing information we may hold about you in order to provide information about our services for recruitment purposes; this may include names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation
For individuals associated with our clients we may hold contact information such as names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation
For individuals associated with our suppliers and other third parties we interact with, we may hold contact information such as names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation
We also need other information such as your bank details so that we can pay for the services you provide
We collect a limited amount of data from our website users which we use to help us to improve your experience when using our website or mobile apps and to help us manage the services we provide. This includes:
information such as how you use our website
the frequency with which you access our website
the times that our website is most popular
IP address (automatically collected)
web browser type and version (automatically collected)
operating system (automatically collected)
a list of URLs starting with a referring site, your activity on this Site, and the site you exit to (automatically collected)
Equal opportunities monitoring and other sensitive personal data
We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we will (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of "diversity information". This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. This diversity information is what is called ‘sensitive’ or ‘special category’ personal information and slightly stricter data protection rules apply to it
Where appropriate and in accordance with local laws and requirements, we'll use this information on an anonymised basis to monitor our compliance with our equal opportunities policy. We will also disclose this (suitably anonymised where relevant) data to clients (including to their internal or external auditors) where this is contractually required or the client specifically requests such information to enable them to comply with their own employment processes
We will collect other sensitive/special category personal data about you such as health-related information or religious affiliation if this is appropriate in accordance with local laws. In such circumstances we'll use this information to comply with employment rights and obligations, such as to calculate entitlement to annual leave or in order to make reasonable adjustments for candidates. We will never do this without your explicit consent
You have the right to withdraw your consent at any time, details of which are under ‘How to amend or withdraw consent’
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims
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:
Entering your details on our website or via an application form, as part of the registration process
Leaving a hard copy CV or business card at a Franklin Fitch event or office;
Emailing your CV to a Franklin Fitch consultant or being interviewed by them;
Applying for jobs through a job aggregator (such as Indeed), or a Job Board (such as Reed or TotalJobs)
Subscribing to receive our Newsletter, Client industry updates or details of upcoming events
Where we contact you, either by phone or email, or through our consultants' business development activities more generally.
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:
We collect contact details where a referee may disclose personal information about you in order for you to serve as a referee
Our Clients may share personal information about you with us
We may collect your personal data from third parties (for example via social media, professional networking, job aggregators e.g. Indeed and job site providers e.g. Reed, LinkedIn)
If you 'like' our page on Facebook or 'follow' us on Twitter we will receive your personal information from those sites
In some circumstances your details may be referred to us through personal contacts, networks or suppliers in reference to specific job opportunities
From third party market research and by analysing online and offline media
From delegate lists at relevant events
From other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them)
In some circumstances your details may be referred to us through personal contacts, networks or suppliers in reference to specific partnership opportunities
If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice. You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time
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:
Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment
Providing you with our recruitment services and to facilitate the recruitment process, including a record of any correspondence or communication between you and us
Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs
Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you
Carrying out our obligations arising from any contracts entered into between us
Carrying out our obligations arising from any contracts entered into between Franklin Fitch and third parties in relation to your recruitment
If you agree, Our Company will share your data with our partner companies so that they may offer you their products and services. For example, we may use Hinterview to send video answers to questions for clients
Facilitating our payroll and invoicing processes
Carrying out customer satisfaction surveys
Verifying details you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties;
Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you (see marketing section below)
If you provide us with information about 3rd parties, we will assume that the 3rd party in question has given you permission to do so and to Franklin Fitch collecting, processing and transferring their Personal Information to the same extent as yours.
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:
Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities
Keeping records of our conversations and meetings, so that we can provide targeted services to you
Undertaking customer satisfaction surveys
Processing your data for the purpose of targeting appropriate marketing campaigns (see below).
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:
To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements
To offer services to you or to obtain support and services from you
To perform certain legal obligations
To help us to target appropriate marketing campaigns
In more unusual circumstances, to help us to establish, exercise or defend legal claims.
We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
In certain circumstances you have the right to object and can find out more under How to amend and withdraw consent.
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:
send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you;
display promotional excerpts from your details on the Franklin Fitch website as a success story (only where we have obtained your express consent to do so)
provide you with information about certain discounts and offers that you are eligible for by virtue of your relationship with Franklin Fitch
for other legitimate business purposes such as producing statistics, analysing how successful our marketing campaigns are, the number of visitors to our website
We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent
If you do not wish to receive any marketing correspondence, you have the right to withdraw your consent at any time and the process for doing this is covered under ‘How to amend or withdraw consent’.
We want to you aware that in some rare circumstances even if you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again
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?
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings
to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
to help us advertise jobs to you that we think you'll be interested in. Hopefully this means less time for you trawling through endless pages and will get you into the employment you want more quickly
Cookies are either:
Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see ‘Advertisement cookies’ below).
Cookies can also be categorised as follows:
Strictly required cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Functionality cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular. Furthermore these cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
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.
The information generated by the cookies about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google undertakes not to associate your IP address with any other data held by Google
If you want to delete these cookies, please follow instructions on how to delete cookies.
We will share your personal data with various parties, in various ways and for various reasons. This can include:
Candidates: Primarily we will share your information with prospective employers or clients to increase your chances of securing the job you want. Unless you specify otherwise, we will also share your information with selected job aggregators where we feel this will help us to provide you with the best possible service and maximise your chances of getting what you want. We may share your information with third parties e.g. Hinterview, where we may ask you to answer some questions for video content to send to clients. Our clients will be the data controller for that Candidate Data
We may disclose information to our group companies
Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies
Clients: We will share your data primarily to ensure that we provide you with a suitable pool of candidates
Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation)
Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems)
Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place
Marketing technology platforms and suppliers
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
In the case of Candidates and our Candidates' and prospective members of Staff's referees: third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws
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)
Data is stored in a UK-based ATS system with our third party CRM supplier in secure locations
This notice and our procedures for handling personal data will be reviewed as necessary.
We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations
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 the Site; any transmission is at your own risk. Once we have received your information, we will use the strict procedures and security features referred to in this clause to try to prevent unauthorised access.
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and/or our data protection officer
If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible
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.
How to amend and withdraw consent
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 firstname.lastname@example.org. 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:
ask you to verify your identity, or ask for more information about your request; and
decline your request where we are legally permitted to do so (but we will explain why if we do so).
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.
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 email@example.com
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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