TABLE OF CONTENTS
1 - INTRODUCTION
2 - DEFINITIONS
4 - COOKIES
11 - SECURITY
20 - PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT;REQUIREMENT NECESSARY TO ENTER INTO A CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA
22 - CONTACT US
We are delighted that you have shown interest in the services of Recann (hereinafter referred to as “Recann”, “we”, “us”, and “our”) which are provided via https://www.recann.co.uk/, and the services provided through the website and our software, APIs, or otherwise and mobile website and mobile applications related, linked, or otherwise connected thereto (collectively the “Services” or “Service”). Data protection is a particularly high priority for Recann. The use of Recann’s Service is possible without any indication of personal data; however, if a data subject wants to use special services via our website or Services, processing of personal data may become necessary. If the processing of personal data is necessary, and there is no legal basis for such processing, we generally obtain consent from the data subject. Recann provides recruitment related services and we will, therefore, use your personal data in order for us to be able to deliver these services to you whether you are a; candidate, client or website user. Recann is deeply committed to ensuring the privacy and protection of your personal information. This includes any information that may be collected during the process of finding you a job, maintaining a relationship with you after placement, offering a service to you, receiving a service from you, utilizing your data to request assistance in relation to one of our candidates, or during your visit to our website or Services. Recann recognizes the importance of privacy and takes great care to uphold the confidentiality of all personal information that is collected.
The processing of personal data, such as the name, address, email address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Recann. Utilizing this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed through this data protection declaration, of the rights to which they are entitled.
As the controller, Recann has applied numerous technical and organizational measures to ensure the complete protection of personal data processed. However, Internet-based data transmissions may, in principle, have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g., by telephone.
The data protection declaration of Recann is based on the terms used by the European laws for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be comprehensible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, among other things, the following terms:
A) Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
B) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which are performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
D) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymization means processing of personal data in a way that it can no longer be linked to a specific data subject without the use of additional information, provided that such additional information is kept separate and protected with special measures to make sure that the personal information cannot be linked back to an identified or identifiable natural person.
G) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data during a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities must adhere to the applicable data protection rules according to the purposes of the processing.
Third-party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, through explicit declaration or clear positive action, indicates agreement to the processing of personal data relating to him or her.
3 NAME AND ADDRESS OF THE CONTROLLER
The Controller for the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is Recann including our holding, subsidiary and other associated companies which are specified in our Data Protection Agreement.
Tel: 0161 711 0791
The data subject may, at any time, prevent the setting of cookies through our website or Services subject to applicability, by employing a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject disables the setting of cookies in the Internet browser used, not all functions of our website or Services may be entirely usable.
5 COLLECTION OF GENERAL DATA AND OTHER SPECIFIC INFORMATION
- The browser types and versions used,
- The operating system used by the accessing system,
- The website from which an accessing system reaches our Services (so-called referrers),
- The sub-websites,
- The dates, times, and frequency with which you access our service,
- An Internet protocol address (IP address),
- The Internet service provider of the accessing system,
- Email address,
- Payment method details such as credit card details
- Phone numbers and,
- Any other similar data and information that may be used in the event of attacks on our information technology systems
Data collected from Candidates.:
Depending on the relevant circumstances in line with local laws and obligations we will most likely collect some or all of the information detailed below in order for us to offer you employment options in line with your circumstances and interests:
- Contact Details,
- Registered address
- Date of birth
- Professional profiles available in the public domain, e.g., LinkedIn, Twitter, or Facebook (We may also collect data from reviewing market & business trends through the analysis of online and offline media and from delegate lists at events,
- Skillset (if not already covered in your CV),
- Job preferences (if not already covered in your CV),
- Current employer/client,
- Your right to work, when requested by our client which may include a photograph, nationality, place of birth, birth certificate, driving license, etc,
- Current salary/employment conditions,
- Desired salary/employment conditions
- Other documentation, if requested by our clients (e.g., references),
- Marital status,
- Bank account and national insurance number (so we can make payments to you and account for tax if you are working as an agency worker supplied through Recann,
- Online skill tests,
- Details of health/disabilities (where you choose to provide this data and it is relevant),
- Marketing and Communications Data: data that we capture when you sign up for our newsletters, including your preferences regarding receiving marketing communications from us,
- Education Details,
- Employment History,
- Emergency Contact Details,
- Referee Details,
- Your right to work status,
- A copy of your driving license/passport /identity card (if requested by a client to fulfil our obligations with them on your behalf)
- Financial Information (where we need to carry out financial background checks if requested by a client to fulfil our obligations with them on your behalf),
- National Insurance Number (if requested by a client to fulfil our obligations with them on your behalf),
- Details of Criminal Convictions if this is requested for a role that you are interested in applying for,
- Details about your current and expected salary, pensions & benefits arrangements,
- Information on your interests and needs regarding future job opportunities,
- Any additional information you choose to disclose to us, and any additional information your referees disclose to us,
- Any additional information our clients disclose to us or that we find from a third party such as a job board,
- A lot of the above data will only be collected as part of a pre-screening call with one of our consultants. Upon initial contact, we will process the data that you have made available on your CV or third-party profiles such as profiles filled out on a job board or networking site.
Data collected from Clients:
The client data we collect is fairly minimal. In line with the information, we require to operate our business as a provider of recruitment services, but will incorporate the following:
- Company name,
- Company address,
- Company phone number,
- Contact Name,
- Contact Details,
- Any information you have chosen to disclose as part of our business dealings,
6 HOW DO WE USE YOUR DATA?
All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR).
Our main focus is on providing recruitment services. Therefore, the main purpose of processing personal data is centred on providing candidates. We will use these details when we deem it necessary based on our legitimate interest, which is our legal basis for processing your data. For more information, please refer to our legal bases for processing your data mentioned herein.
When using these general data and information, Recann does not draw any conclusions about the data subject. Rather, this information is needed for:
- Storing your details on our database so that we can contact you about recruitment services,
- Keeping records of conversations and meetings so that we can tailor our services to you,
- Processing your data for the purpose of targeting appropriate marketing campaigns,
- Deliver the content of our Services correctly,
- Optimize the content of our Services as well as its advertisement,
- Ensure the long-term viability of our information technology systems and website technology,
- For analytics purposes,
- To facilitate account creation and logon process,
- Request feedback,
- As necessary for the basic functionality of the Services and account management (billing our clients),
- Providing law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack,
- Offering a recruitment service that includes a dedicated account manager and up-to-date job listings,
- Managing access to our Services and personalize your experience on it,
- Responding to your communications and send you email newsletters, alerts, etc. that you have subscribed to. You can unsubscribe at any time by clicking on the unsubscribe link in every email,
- Analysing your use of our Services and gather feedback to improve it and your user experience,
- Collecting data from you and other sources, such as LinkedIn, to store your details on our database so that we can contact you regarding recruitment,
- Providing you with recruitment services and assisting you in the recruitment process,
- Assessing your data against vacancies that could be of interest and suitable to you,
- Sending your information to clients to apply for jobs we have discussed with you and evaluate your eligibility for those jobs,
- Allowing you to upload your CV to client online portals to introduce you to opportunities,
- For fulfilling contractual agreements entered into and carrying out agreements on your behalf with third parties and clients in relation to recruitment,
- Processing payments through payroll or invoice processes,
- Carrying out customer satisfaction questionnaires,
- Processing your data to update you with relevant job opportunities that align with your expectations,
In some cases, we may be legally required to collect certain data, and we will not be able to provide you with our services without your consent for us to use that data.
With your permission and where permitted by law, we may use your data for marketing purposes, such as contacting you by email, phone, text, or mail with information, news, and job listings. We will not send unsolicited marketing or spam and will protect your rights and comply with data protection laws.
Under GDPR, we ensure that your personal data is processed legally, fairly, and transparently and we will only process your personal data if one of the following applies:
- you have given consent for specific purposes,
- processing is necessary for a contract or to take steps before a contract,
- processing is necessary to comply with a legal obligation,
- processing is necessary to protect your or someone else's vital interests,
- processing is necessary for a task in the public interest or official authority,
- processing is necessary for our legitimate interests, except where they override your fundamental rights and freedoms,
- If you are a candidate looking for employment, we may hold or process your data in your legitimate interests and will ask for your permission and active consent to share your details with potential employers. You can let us know if you no longer want your details shared. You are within your rights under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015 regulations to declare which personal details we share with potential employers. For example, only phone number and name or only name and email address.
- If you are an employer looking for candidates, we will only share and process data on an individual who has given us express permission and active consent to do so. Similarly, we will only share your personal data as an employer with your prior active consent.
- If you no longer wish for your details to be shared in this way please let Us know or email firstname.lastname@example.org.
- Therefore, Recann analyses anonymously collected data and information statistically, with the goal of enhancing the protection and security of Recann’s data and to achieve the best level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
7 REFERRING A FRIEND CRITERIA
In order to participate in the referral program, you (referred to as the “Referee") must be a registered member of Recann.
The individual you are referring must not already be registered with Recann, and you are not allowed to refer yourself or any family member. Any taxes resulting from referral fees provided by Recann will be the responsibility of the referee.
If the Referee refers a person who is placed in a position by Recann and the person successfully completes their probation period with a client (for permanent placements) or completes 6 months of an assignment (for contract placements), the Referee will be eligible to receive up to £500.00 payment or voucher.
The referral voucher is only payable upon initial placement and is not applicable for further placements.
The Referee must be over 18 years of age at the time of submitting the referral.
The referred person must be informed and must consent to their details being passed to Recann for this scheme before the date of referral. This is the responsibility of the Referee and must comply with GDPR. The Referee will be liable for any loss or claim arising from their failure to obtain such consent.
Recann reserves the right to change the terms of the referral scheme or cancel the scheme without notice.
In case of any dispute, Recann's decision will be final.
8 OUR ENTITIES AND HOW WE HANDLE YOUR INFORMATION
Your personal data will be kept on our company's CRM database and can be accessed by our employees in various international locations. All of our offices, including those abroad, will follow GDPR guidelines when handling your personal data. Additionally, in the event that Recann buys or sells a business or assets, your information may be shared with the potential buyer or seller. Lastly, we may also be required to share your information to comply with legal obligations, defend against legal claims, or protect the rights and safety of Recann and others.
9 MARKETING ACTIVITIES
We may use your data for marketing purposes, such as informing you about similar job opportunities to the one you applied for or submitted your CV for, when you have supplied your data by applying for a job or submitting your CV to us and when you have made your CV available via a third-party online job board. We may also reach out to you through a Soft Opt In approach, where we have had previous engagements with you., and we are promoting recruitment-related services. We will most likely only contact you by email to suggest other jobs that could be of interest, in line with the original role we gathered your details for, in order to increase the chances of finding you a new position. For any other type of e-marketing, we are required to obtain your specific consent.
You have the right to object to us processing your data for the purposes of direct marketing and you can do so by sending us an email at email@example.com. If you prefer for Recann to no longer retain your details, please do so by sending us an email at firstname.lastname@example.org and Recann will completely remove you from our system.
10 CONTACT POSSIBILITY VIA THE WEBSITE (SERVICES)
Recann’s website (Services) provide information for quick electronic communication with Recann, as well as direct communication with us, which also includes an email address. If a data subject contacts Recann by email or via a contact form, the personal data sent by the data subject are automatically stored. Such personal data sent on a voluntary basis by a data subject to Recann are stored for the purpose of processing or contacting the data subject.
Recann makes sure that the data is secured with encryption when being transmitted outside of the Services. This means changing the information into a secret code so that nobody who isn't allowed to can see it. The Services use this process and use safe methods to make sure all credit and debit card payments are protected. To protect customer information while it's being sent to and from the Services, encryption methods like SSL are used to create a secure connection.
Whilst we do everything within our power to ensure that personal data is protected at all times from our Services, we cannot guarantee the security and integrity of the information that has been transmitted to our Services.
12 ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA
Recann shall only use and keep the personal information of the person it belongs to for as long as it is needed to achieve the purpose for which it was stored, or as far as this is allowed by the European laws or other laws or regulations to which Recann is subject.
If the storage purpose is not applicable, or if a storage period prescribed by the European laws or other laws expires, the personal data are routinely blocked or erased in accordance with legal requirements.
13 RIGHTS OF THE DATA SUBJECT
A) Right of confirmation
Each data subject shall have the right given by the European law, to ask the controller if they are processing their personal data. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact us or another employee of the controller.
B) Right of access
Each data subject shall have the right given by the European law receive free information from the controller about his or her personal data stored at any time and a copy of this information. The European directives and regulations grant the data subject access to the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing; the existence of the right to file a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source; the existence of automated decisionmaking, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may at any time contact us or another employee of Recann.
C) Right to rectification
Each data subject shall have the right, given by European law, to receive their personal data without undue delay and correct any inaccurate personal data the controller may have about them. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact us or another employee of Recann.
D) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the given by European law to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing in accordance with Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which Recann is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Recann, he or she may at any time contact us or another employee of Recann. Recann or another employee shall promptly ensure that the erasure request is complied with immediately.
Where Recann has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, Recann shall, taking account of available technology and the cost of implementation take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. Recann or another employee will arrange the necessary measures in individual cases.
E) Right of restriction of processing
Each data subject shall have the right granted by the European laws to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period allowing the controller to verify the accuracy of the personal data.
The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
The controller no longer needs the personal data for the processing, but they are required by the data subject for the establishment, exercise, or Defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of Recann prevail those of the data subject.
If one of the conditions as mentioned above is met, and a data subject wishes to request the restriction of the processing of personal data stored by Recann, he or she may at any time contact us or another employee of Recann. Recann or another employee will arrange the restriction of the processing.
F) Right to data portability
Each data subject shall have the right granted by the European laws, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used, and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided. As long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact Recann or another employee.
G) Right to object
Each data subject shall have the right granted by the European laws to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Recann shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or Defence of legal claims.
If Recann processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Recann processing for direct marketing purposes, Recann will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her by Recann for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may directly contact Recann or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
H) Automated individual decision-making, including profiling.
Each data subject shall have the right granted by the European laws not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Recann shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact Recann or another employee of Recann.
I) Right to withdraw data protection consent
Each data subject shall have the right granted by the European laws to withdraw his or her consent to the processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact Recann or another employee of Recann.
14 DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF THE FOLLOWING SERVICE PROVIDERS
Recann uses or has integrated (in the Services) the components of:
- BullHorn CRM –Bull Horn CRM is used for customer management and helping match candidates with appropriate positions. The data will be stored securely and is protected by Privacy Shield protocols of the service provider. Bull Horn is committed to protecting your data and the applicable data protection provisions of BullHorn CRM may be retrieved under. https://www.bullhorn.com/gdpr-commitment-statement/
- Broadbean –Broadbean online recruitment software is used for job posting and distribution, CV database search, social referral, job alerts, and data analysis. The applicable data protection provisions of Broadbean may be retrieved under http://info.broadbean.com/broadbean-gdpr.
- Lusha –Lusha is utilized by us to enrich social profiles and attribute contact details to social media profiles. We will occasionally copy details from Lusha to notify the data subject of relevant jobs. The applicable data protection provisions of Lusha may be retrieved under: https://www.lusha.co/gdpr.
- Hunter.io –Hunter.io or email hunter is utilized by us to verify correct email addresses against a pseudonymised and speculative email address verification process. The applicable data protection provisions of Hunter.io may be retrieved under: https://hunter.io/gdpr.
- Reed – Reed is an online job portal and recruitment service. We use Reed to post jobs, find candidates and match them to job opportunities for employers. Reed data storage policies can be found here: https://www.reed.co.uk/policies. We will often process data from Reed by copying contact information from the service and matching these to our current records or creating a new data subject record to match.
- CV Library – We use CV Library to post jobs, find candidates and match them to job opportunities for employers. CV Library’s data storage policies can be found here: https://www.cv-library.co.uk/gdpr-statement. We will often process data from CV Library by copying contact information from the service and matching these to our current records or creating a new data subject record to match candidates to jobs.
- Stepstone & its Subsidiaries – (CW Jobs, Total Jobs, JobSite, Mahiba) – We use CW Jobs, Total Jobs and JobSite to post jobs, find candidates and match them to job opportunities for employers. This group’s data storage policies can be found here: http://recruiters.cwjobs.co.uk/page/gdpr, https://www.totaljobs.com/privacy-policy, https://www.jobsite.co.uk/privacy We will often process data from this group of websites by copying contact information from the service and matching these to our current records or creating a new data subject record to match candidates to jobs.
- Monster Jobs – We use Monster to post jobs, find candidates and match them to job opportunities for employers. Monster’s data storage policies can be found here: http://inside.monster.co.uk/fullpolicy/inside2.aspx. We will often process data from this group of websites by copying contact information from the service and matching these to our current records or creating a new data subject record to match candidates to jobs.
- Cognism - The data we are using to contact you with has been sourced through Cognism using publicly available sources. We are contacting you under 6(1) lit. f GDPR ‘legitimate interest’ basis. Recann may have obtained some or all of your personal information about you from Cognism. For more details about the types of business-to-business information Cognism collects and shares with third parties, see this page on the Cognism website: https://www.cognism.com/b2b-data.
- Zoominfo - The data we are using to contact you with has been sourced through Zoominfo.com using publicly available sources. We are contacting you under 6(1) lit. f GDPR ‘legitimate interest’ basis. ZoomInfo processes only business contact information in the EU: company, job title, work email address, work phone number, etc. It does not provide sensitive personal information of any kind. It simply provides the type of information that is typically found on a business card, an email signature block, or a public professional profile. To find out more visit https://www.zoominfo.com/about-zoominfo/privacy-policy.
- Selligence - Selligence may share your personal data with us to contact you under 6(1) lit. f GDPR ‘legitimate interest’ basis. Sellignece provides limited access of its database. We may use the information provided by Selligence to contact individuals in relation to recruiting activities or business opportunities. To find out more visit https://www.selligence.com/privacy-policy.
- Rocket Reach - We may use your information provided by Rocket Reach to contact you under 6(1) lit. f GDPR ‘legitimate interest’ basis. RocketReach processes data in the USA and guarantees compliance with data protection regulations in the EU via [EU Standard Contractual Clauses] https://rocketreach.co/privacy https://rocketreach.co/gdpr
- Contactout - We may use your information provided by Contactout to contact you under 6(1) lit. f GDPR ‘legitimate interest’ basis. To know more about the features of Contactout, visit https://contactout.com/ . Contactout’s privacy practises may be found at https://contactout.com/privacy_policy.
- SignalHire - SignalHire offers various services and tools designed specifically for recruiters, marketers, and HR specialists who are seeking to make contact with business professionals for employment or marketing purposes, or to obtain industry, market or competitor analysis. We may use your information provided by Contactout to contact you under 6(1) lit. f GDPR ‘legitimate interest’ basis. To know more about the privacy practises of SignalHire, visit https://www.signalhire.com/privacy.
- Google Analytics (with anonymization function) – Recann has integrated the component of Google Analytics in the Services (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service gathers, among other things, information about the website from which a person originated. (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
- YouTube – Recann has integrated components of YouTube in the Services. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
Further information about YouTube may be obtained at https://www.youtube.com/yt/about/en/.
YouTube and Google will receive information through the YouTube component that the data subject has visited our website (Services) if the data subject at the time of the call to our Services is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If the transmission of this information to YouTube and Google is not desired by the user, it can be prevented by logging out of their YouTube account before accessing our Services.
15 DATA STORAGE LOCATIONS
Your data will be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using the Services and submitting information to us. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand and we have put in place safeguards to protect your personal data which are discussed in our Data Protection Agreement.
16 SHARING OF PERSONAL DATA WITH THIRD-PARTIES
In compliance with all local laws and regulations, your data may be shared for any of the following reasons:
- Individuals and companies that have information about your reference or application to work with Recann, including current, past, and potential employers, educational institutions, examination bodies, and employment and recruitment agencies.
- Tax, audit, or government bodies when requested by law.
- Third-party service providers who carry out work on our behalf, such as professional advisers, IT service providers, and outsourced IT and document storage providers with whom we have a processing agreement or similar protection in place.
- Marketing technology Services
- Potential employers to process your application for roles.
- Third parties for technical testing or clients that use online talent management systems.
- If relevant and with your prior active consent, we may share your data with companies that have relevant job openings for each job.
- We may contract with third parties to supply some services to you on your behalf. These may include payment processing, search engine facilities, advertising, and marketing. In every circumstance, your data will be encrypted and only contractors who have been thoroughly vetted will be able to see your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law. We currently contract with the entities as mentioned in our Data Protection Agreement.
17 LEGAL BASIS FOR THE PROCESSING
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example, in the case of inquiries concerning our services. If we are subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European laws. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
18 THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY
19 PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract. If the data subject requests for termination or terminates his Recann Account, the personal data shall be retained for a period of 1 year from the date of termination.
20 PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT; REQUIREMENT NECESSARY TO ENTER INTO A CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA
We clarify that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). It may be required in certain circumstances to enter into an agreement where the data subject provides us with their personal data, which will then be processed by us.. The data subject is, for example, obliged to provide us with personal data when Recann signs a contract with him or her. Failure to provide the personal data would result in the inability to establish a contract with the data subject.. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer (Contact details provided below). Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law, contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
22 CONTACT US
Recann Data Protection Officer (DPO): email@example.com
For general Inquiries: firstname.lastname@example.org