|TSR Education Ltd T/A The Supply Room (‘the Company’)|
|Data Protection Policy (Version 1)|
|01 May 2018|
The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you, we will only use your personal data in accordance with the terms of the following statement.
- Collection and use of personal data
Purpose of processing and legal basis
The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. The legal bases we rely upon to offer these services to you are:
- Consent provided freely by anyone wishing to use the work-finding services offered by the Company
- Legitimate Interest
- Legal obligation
- Contractual obligation
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- We require your personal data to assist you with the recruitment process
Please note that legitimate interests will not be used to process any sensitive personal data. In this case, we will request consent.
Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
- Schools, nurseries, universities, colleges or any other educational institutions (Our Clients & Potential New Clients)
- Disclosure and Barring Service – Should a new enhanced DBS Check be required
- (APCS) Access Personal Checking Services Ltd – Should a Barred List Check be required
- Our Accounting and Payroll Company – For candidates who secure work through the Company
- Anfold Software Ltd – To obtain signed timesheets for completed work electronically
- HMRC and Creative Pensions – For payroll purposes
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data is that you will not be able to use the services offered by TSR Education Ltd.
- Overseas Transfers
The Company may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
- Data retention
The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our retention policy. To request a copy of our retention policy please email our data protection officer, David Dos Santos, at email@example.com. Upon expiry of that period, the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal and sensitive personal data.
- Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company processes on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to the Company processing your personal and sensitive personal data you have the right to withdraw that consent at any time by contacting the data protection officer of The Company; David Dos Santos via email on firstname.lastname@example.org or by calling The Company on 0203 950 0632.
- Source of personal data
The Company may source your personal data by one of the following means:
- From the Company website where you have either applied for a job or registered for work on the site
- From a Jobs Board where the Company have either a job advertising or CV searching license
- From LinkedIn where the Company have been able to access your public profile
Please note once we have obtained this data, we will seek to gain consent, if this is not gained/ granted we will cease to process your data.
- Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact the data protection officer of The Company; David Dos Santos, via email on email@example.com or by calling The Company on 0203 950 0632.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.