PRIVACY POLICY

Last Updated: 22nd May 2023

 

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SECTION 1- INTRODUCTION:

 

Bullhorn Consultants is a recruitment services provider defined in the Employment Agencies and Employment Businesses Regulations 2003. We are also involved in outsourcing services majorly dealing in the same business line – recruitment services. We 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 client contacts;

• Supplier contacts to support our services;

• Employees, consultants, temporary workers;

• Website Users;

 

This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us as the Data Controller for any such data. Your personal information (also called ‘personal data’) is the information which identifies you as an individual that we get from you and others in various ways.

Under the Data Protection Act 1998 (the "Act") and the General Data Protection Regulation 2018 (“GDPR”) specific obligations are placed on us in the way we handle this type of data.

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Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.

 

This privacy policy document outlines the way we collect, use, store, process and disclose your personal information submitted to or collected by us while accessing our website and how you can access and manage this information.

 

SECTION 2 - CONTACT DETAILS:

 

For any matters related to this privacy policy, you can get in touch with us at below address:

 

Bullhorn Consultants Limited

1, Peel Drive, Clayhall

Ilford, Essex

IJ5 0JR

United Kingdom

 

Alternatively, you can reach out to us on gdpr@bullhornconsultants.com for GDPR or compliance related information. For any other information please email us on info@bullhornconsultants.com   

 

In case you do not receive a satisfactory resolution to your concerns or queries, you have the right to approach at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) through following means:

 

Phone: 0303 123 1113

Email: casework@ico.org.uk || Live chat

Post: Information Commissioner's Office, Wycliffe House

Water Lane, Wilmslow

Cheshire SK9 5AF

 

However, we’d appreciate if you provide us an opportunity to resolve your concerns before approaching the ICO. We ensure you that we are ready to go that extra mile to resolve your concerns & queries in a time bound manner. For any requests, queries and concerns pertaining to this Privacy Policy and GDPR compliance at Bullhorn Consultants Limited.

 

SECTION 3 - PERSONAL INFORMATION WE COLLECT OR YOU GIVE US:

 

The personal data we collect or receive includes the following as applicable:

 

• Name

• Address

• Email and other contact details

• Date of birth

• Job history (including information relating to placements through us)

• Educational history, qualifications, certifications & skills

• Visa and other right to work or identity information

• Passport details

• Bank details

• National insurance and tax (payroll) information

• Next of kin and family details

• Contact details of referees

• Personal information relating to hobbies, interests and pastimes

• Information contained in references and pre-employment checks from third parties

• Other sensitive personal information such as health records (see ‘Sensitive Personal Data’ section below)

• Your marketing preferences

 

We may obtain your personal data from the following sources (please note that this list is not exhaustive):

 

• You (e.g. a Curriculum Vitae, application or registration form)

• A client

• Other candidates

• Online jobsites

• Marketing databases

• The public domain

• Social Media such as LinkedIn

• At interview

• Conversations on the telephone or video conferencing (which may be recorded)

• Notes following a conversation or meeting

• Our websites and software applications

 

If we have collected your personal information for a third-party source like an online job site, then it is our policy to inform you about the source of the information.

 

We also collect the personal information through our application forms and contact forms (online or at our offices) which may include any additional comment or remarks that you may add in the free text fields (such as personal statements) or CVs (where applicable).

 

In addition, we may collect, maintain and use the Information about your computer and your visits to, and use of our website. This includes: your location; IP address; browser; operating system; referral source; length of visit; individual page views; site navigation (Usage Data) through technologies like cookies. Please see Section 10 of this article to know more about the type of cookies our website uses and how to disable them.

 

We may also keep a record of references received from third parties (including those you give us, credit reference and fraud prevention agencies) and of any other correspondence or communication between you and us, whether written, e-mailed, or as a result of visits, interviews or recorded telephone calls.

 

While we take all necessary steps to ensure data protection, no information transmitted over the web can be completely secure. We in this way don't ensure the security of individual data that you send to us, or through your use of our website. Any individual data you do send is at your own risk, however once we get it we employ strict strategies and processes to protect it.

 

Please note that we do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless any of this information is included in your resume or CV submitted to us through any channel including online or hard copy handed to us.  Nor do we collect any information about criminal convictions and offences unless freely and willfully provided by you or is bound to be collected under legal or contractual arrangement that we may have entered or are about to enter.

 

SECTION 4: USING YOUR PERSONAL DATA:

 

The personal information you submit to us via our website or at any of our offices through physical means or is collected by us as outlined in Section 3 above will only be used for the purposes specified in this Privacy Policy. We will only use your personal information when the law allows us to.  The most common legal basis on which we would be processing your personal information would be either: 

 

Section 4.1 – Contractual Obligation:

To perform the contract, we are about to enter into or have entered into with you which may include:

• to process your job application and otherwise manage the recruitment process

• enable potential employers assess and process your job application

• enable potential employers check and confirm the references that you provide as part of your job application

• check with any necessary regulatory, industry and/or security authorities relevant to the position that you have applied for

 

Section 4.2 – Legitimate Interests:

Where it is necessary for our legitimate interests (or those of a third party) (read Article 6(1)(f) of the GDPR) and your interests and fundamental rights do not override those interests. This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes. We may thus be:

 

• Using your personal data to:

  • assess suitability and contact you regarding potential opportunities and/or our services

  • collate market information or trends including providing analysis to potential or actual Clients

  • source potential opportunities or roles as part of our Recruitment Services

  • personalize your experience and our offering, whether via our website or otherwise

 

• Retaining records of our dealings and transactions and where applicable, use such records for the purposes of

  • establishing compliance with contractual obligations with Clients or suppliers​

  • addressing any query or dispute that may arise including establishing, exercising or defending any legal claims

  • protecting our reputation

  • maintaining a backup of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach

  • evaluating quality and compliance including compliance with this Privacy Notice

  • determining staff training and system requirements

 

Section 4.3 - Legal or Regulatory Obligations:

Where we need to comply with a legal or regulatory obligation as required by the law of the land.

 

Section 4.4 – Consent:

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.

We will, in some circumstances, rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. An Example of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).

 

SECTION 5 - PERSONAL INFORMATION DISCLOSURE:

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We may make your personal information available to agencies and employers who subscribe with us or use our Website, working within the ambit defined above in the way we use your data. These clients may then use that information to contact you about specific roles via email, phone or post.

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We may disclose your personal information to any of our employees, officers, agents, suppliers or subcontractors insofar as is reasonably necessary for the purposes as set out in this Privacy Policy.

 

In addition, we may disclose your personal information:

• To the extent that we are required to do so by law.

• In connection with any legal proceedings or prospective legal proceedings.

• In order to establish, exercise or defend our legal rights. Including providing information to others for the purposes of fraud prevention and reducing credit risk.

• To the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling.  Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy.

• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

 

Except as provided in this Privacy Policy, we will not provide your information to any other third parties. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions and policies outlined in this document only.

 

SECTION 6 - RETAINING AND DELETING PERSONAL DATA:

 

Although we would not retain your personal information for more than 12 months from the point we had provided you with any recruitment service or have engaged with you. We may retain your personal information for more than 12 months if we are required to do so under legal or contractual obligations. We have a strict policy to retain data only when we find it necessary to comply to legal, contractual obligations or if the data is for our legitimate business interest.

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If you’d still like us to delete your personal information prior to the periods mentioned above, you may request the same at any time. Please refer to the section “Your rights” for more information. Any such request would only be considered on case to case basis and as per the procedures outlined in Section 9 on this policy document.

 

SECTION 7- TRANSFER OF DATA TO OTHER JURISDICTIONS

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In the course of the provision of our Recruitment Services we may transfer data to countries or international organizations outside of the European Economic Area (EEA). This may, for example, be to Clients or Candidates, or third parties who provide support services to us.  Where information is to be so transferred, it may be to a country in respect of which there is an adequacy decision from the EU Commission. However, if this is not the case, it is our policy to take steps to identify risks and in so far as is reasonably practicable, ensure that appropriate safeguards are in place.

 

SECTION 8 - CHANGES TO THIS PRIVACY NOTICE

 

We ensure that we comply with the latest statutory developments governing our business and thus we regularly review and update this privacy policy from time to time to reflect changes in our business, or legal or commercial practice.  Where an update is relevant to our processing of your data, we shall notify you of the same or you can visit this space again if you’d like to be updated on the same. We always mention the date of last update of the policy on the top of this document for your reference.

 

SECTION 9 - YOUR RIGHTS:

 

• 9.1: Requesting access to your personal information; You can at any time request access to the data that we have in our database. In order to do so you will be needed to submit a Subject Access Request (SAR) by submitting an application to gdpr@bullhornconsultants.com. Although we would take all necessary steps to ensure that we deliver this information to you without any undue delay. There might be cases where:

 

• We will ask you to verify your identity or request more information about your request to ensure that the information is handed to the rightful owner of the data.

• We may decline your request, where we are legally permitted to do so while providing you with the appropriate reason to chose this action.

 

• 9.2: Requesting correction of your personal information; The accuracy of your data is of prime importance to us, thus if you feel the information held with us is not correct or incomplete. You can always request us to rectify the information by writing to us through post or getting in touch with us on gdpr@bullhornconsultants.com. We will respond to such request within 30 working days from the date of receiving such request.

 

• 9.3: Requesting erasure of your personal information; You can also request for the deletion of your personal information from our records, only if we are not legally bound to keep such information to comply with prevailing employment and business regulations including but not limited to Regulation 29 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003. Any such request may be submitted to us by post or through email on gdpr@bullhornconsultants.com.

 

• 9.4: Objecting to processing of your personal information; If we are using ‘legitimate interests’ as the legal basis of processing your data, you have the right to object to such processing. Any such requests must be submitted to us through post or through email on gdpr@bullhornconsulants.com, we will ensure that such requests are addressed within 30 working days of receipt at our end. Commonly, we will only disagree with you if certain limited conditions apply.

 

• 9.5: Requesting restriction of processing your personal information; You have the right to request restriction of processing your personal information in certain cases which excludes any legal obligation that we may be fulfilling under the prevailing laws of the land.

 

• 9.6: Request transfer of your personal information; You have the right to request us to transfer your data to another data controller or directly to you in a commonly used readable format.  This right only being applicable where our processing of your data is based either on your consent or in performance of a contract.

 

• 9.7: Right to withdraw consent; If we’ve used your consent as a legal basis to process your data, you have the right to withdraw the consent thereby restricting us to use your personal information on the basis of consent. However, we may continue to retain, or otherwise use your personal information thereafter if there is a legal or contractual obligation on us or we have a legitimate interest in doing so.

       

If in case you’d like to exercise any of the rights mentioned above in this section, you can reach out to us through post or by sending an email to gdpr@bullhornconsultants.com. We will take utmost care that we address your request and queries within the stipulated timelines. If in case there would be any delays, the same shall be communicated to you along with appropriate reasons of the delay.

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SECTION 10 - COOKIES:

 

Cookies are small pieces of data stored on a site visitor's browser, usually used to keep track of their movements and actions on a site. They are helpful in remembering your preferences and enhance site performance. You may choose to decline the use of cookies by following the instruction below, however it may impact the site’s performance and you may not be able to use all the website features completely.

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10.1 - Cookies we use

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By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services.

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Below is a list of the cookies that our website uses for various purposes as highlighted: