Last Updated 14th May 2018
So Code Limited takes your privacy seriously.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The GDPR will be applicable in the United Kingdom from 25th May 2018
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Who are So Code and what do we do?
So Code are a Recruitment Agency operating in the UK Technology Recruitment space. We retain the personal data of several stakeholders which allow us to undertake our business.
We collect the personal data of the following types of people to allow us to undertake our business:
Clients - (Prospective and Current Managers / Contacts)
Candidates - (Prospective and Current Permanent and Consultants/Contractors)
Suppliers and Third Parties – Business Partners supporting our services.
Employees – Direct So Code Employees.
Information we may collect from you
We may collect and process the following data about you:
You may give us information about you by filling in forms on our site socode.co.uk or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site, enter a promotion or survey, during the course of any other activity commonly carried out on our site and when you report a problem with our site. The information you give us may include (but not be limited to) your name, address, email address and phone number, personal description, job history, qualifications and photograph.
With regard to each of your visits to our site we may automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plugin types and versions, operating system and platform;
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page and any phone number used to call our customer service number.
What if we obtain your personal data from a third party?
Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.
Why we process your personal data:
1. Compliance with legal obligations (regulatory and statutory obligations):
We must comply with a number of statutory provisions when providing our Recruitment Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things requires us to assess suitability of candidates and obtain information from Clients.
We are also required to comply with statutory and regulatory obligations relating to business generally, for example tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities such as HMRC.
2. Our legitimate interests (carrying on the commercial activity of Recruitment Services):
In providing our Recruitment Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:
- Using your personal data:
-- to contact you regarding our Recruitment Services
-- to assess suitability of Candidates and roles, for example, referencing or other feedback
-- to collate market information or trends including providing analysis to potential or actual Clients
-- as otherwise necessary to provide our Recruitment Services and/or to meet our obligations towards either the party whom you represent, or other Clients or suppliers
-- to personalise 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 back up 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
For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason, for example references.
You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.
Disclosure of your information inside and outside of the EEA
We will share your personal information with:
Selected third parties including:
- clients for the purpose of introducing candidates to them
- candidates for the purpose of arranging interviews and engagements
- clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you
- subcontractors including email marketing specialists, event organisers, timesheet, payment and other financial service providers
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users
- analytics and search engine providers that assist us in the improvement and optimisation of our site
- credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If So Code Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
The lawful basis for the third party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs
- satisfaction of their contractual obligations to us as our data processor
- for the purpose of a contract in place or in contemplation
- to fulfil their legal obligations.
Where we store and process your personal data
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention policy and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
- prior to making an introduction we check that we have accurate information about you
- we keep in touch with you so you can let us know of changes to your personal data.
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
- the nature of the personal data
- its perceived accuracy
- our legal obligations
- whether an interview or placement has been arranged
- our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. Our current retention policy is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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.
The GDPR provides you with the following rights. To:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below)
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
- Request the transfer of your personal information to another party in certain formats, if practicable
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/ .
- Access to information The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Contact & Questions
So Code have a dedicated Data Officer – Emily Mills, who can be contacted as below:
firstname.lastname@example.org / 01223 656 729
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. Please read the policy carefully to understand our views and practices regarding your personal data and how we will treat it.