Industry Club (a trading name of Theworkclublondon Limited; company number 07481831) and its group company, The Industry School Limited (company number 10973347), (together the “Company/we/us/our”) are the data controller and are committed to respecting and protecting Your privacy. This Privacy Notice is provided for our prospective, existing and former clients, customers and candidates, as well as users of this website.
We will only process Your personal data in accordance with this Privacy Notice (and any other information we give to you about how we process Your personal data), and in accordance with the current and future Data Protection Legislation.
The Data Protection Legislation means:
- the Data Protection Act 1998 (until it is replaced)
- the General Data Protection Regulation ((EU) 2016/679) (GDPR) for so long as the GDPR is effective in the UK;
- and any replacing legislation for the Data Protection Act 1998 and the GDPR, in particular the Data Protection Bill 2017-2019, once it becomes law.
DATA PRIVACY MANAGER
Our Data Privacy Manager can be contacted at firstname.lastname@example.org
If you have any questions about how we process your data or would like to exercise any of your rights under the Data Protection Legislation, please contact the Data Privacy Manager using this email address.
CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO KEEP US INFORMED
This version was last updated on Friday 11th May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We reserve the right to make changes to this Privacy Notice from time to time. If this Privacy Notice changes in any way, We will place an updated version on our Website. Regularly reviewing our Website ensures that You are always aware of what information We collect, how We use it and under what circumstances, if any, We will share it with other parties.
INFORMATION WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about you from which you can be identified. It does not include data where your identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our group companies and your communication preferences.
WE OBTAIN YOUR PERSONAL DATA FROM
- You. By the provision of your CV via email or our website, when you give Us information via email or online private mail systems, during a telephone conversation or in person. We give you the option of submitting your CV via this website. You can do this either to apply for a specific advertised job or for consideration by our recruitment consultants for positions as they come up. Your CV will be emailed directly to our recruitment consultants who review your details and enter them onto our central in-house database. This database, including the information relating to you, can be accessed by any of our recruitment consultants working in the Company. We also obtain personal data from you when you request information on our available training services or place an order for a training course or other services.
- Automated technologies or interactions. As you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below for further details on cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical data (including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website), including analytics providers such as Google based outside the EU;
- Identity and contact data from publicly availably sources such as Companies House and the Electoral Register;
- Status, experience and qualifications (including CV’s) from third parties including job boards including Campaign Jobs, Linkedin and other industry relevant boards.
- From your referees, details of whom you will have provided previously. Please note that this may include our client/your potential employer contacting such referees.
- Contact, Financial and Transaction Data from providers of technical and payment services based inside or outside the EU.
- From your current employer when you are employed by an umbrella/payroll company or personal service company. Please note: In these circumstances, when you are engaged through such a company, we will be relying on your employer to ensure they have established a legal basis for processing your data with you. Our basis for the ongoing processing of your data will become subject to a contract between us and that company.
SENSITIVE AND IDENTIFICATION DATA
For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment law. You will be made aware of this in advance.
In order to verify your identity and to meet legal requirements placed on our clients to validate your right to work in the UK, we request official photo ID such as a passport or driving licence. This data is held securely in our systems and will only used for the purposes of verifying your identity (which may include sharing with a client, but we will let you know about this in advance). We will obtain your consent for this processing at that time and this may be refused or withdrawn at any time. However, this may impact on our ability to find a job for you.
HOW WE MAY CONTACT YOU
The Industry Club provides a very detailed and personal service to candidates for their job search. We will contact you either by telephone or email. This will be possible because we have a legitimate interest as part of providing our service to you and our clients (please see below for more details on our legal basis for processing). This means that you have provided information about yourself on the understanding that we will need to contact you to help you seek new employment.
You can stop these notifications at any time by contacting us at email@example.com.
The Industry School also provides bespoke and supported services, so we will contact you by either phone or email in relation to information on our services, the placing of an order and as part of providing our service to you.
You can also stop these notifications at any time by contacting us at firstname.lastname@example.org.
USE OF TOOLS/COOKIES
When you visit our website(s), we may collect certain information by automated means, such as using cookies. The information we may collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URL’s, information on actions taken on our website(s) and other usage statistics.
- PHPSESSID – This just holds session information and doesn’t store any personal data. It also expires when the browser window is closed.
- Standard analytics.js cookies: _ga _gat _gid
- You can find out details of these cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
- Captcha on the forms uses the Google cookie NID.
When playing a video, YouTube cookies are also dropped. These are:
- IDE (doubleclick)
- PREF (youtube)
- VISITOR_INFO1_LIVE (youtube)
- YSC (youtube)
|PHPSESSID||WordPress (The Industry Club)||Session ID||Session|
|_ga, _gat, _gid||Analytics||Persistent|
|1P_JAR||doubleclick (Google)||Advertising / Tracking||Persistent|
|CONSENT||doubleclick (Google)||Advertising / Tracking||Persistent|
|HSID||doubleclick (Google)||Advertising / Tracking||Persistent|
|SAPISID||doubleclick (Google)||Advertising / Tracking||Persistent|
|SID||doubleclick (Google)||Advertising / Tracking||Persistent|
|SIDCC||doubleclick (Google)||Advertising / Tracking||Persistent|
|SSID||doubleclick (Google)||Advertising / Tracking||Persistent|
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, to provide our recruitment services to you and you fail to provide that data when requested, we may not be able to provide further services or assist you in your job search. In this case, we may have to stop our service, but we will notify you if this is the case at the time.
OUR USE OF YOUR PERSONAL DATA
We may use Your personal data for any of the following purposes:
PURPOSE AND USE OF DATA and LEGAL BASIS
|How we use the information||Legal basis of processing|
|To register you as a new candidate||a) Necessary in our legitimate interests and for you to receive the benefit of our services.|
|To carry out job search and recruitment services and to contact you about potential job roles and our actions on your behalf.||a) Necessary in our legitimate interests and for you to receive the benefit of our services.|
|To provide you with information on our training courses||a) Necessary to comply with your request for information (consent)|
b) Necessary in our legitimate interests to provide you with the information on our services
|To process and deliver your order for training services including:|
a) Manage payments, fees and charges
b) Collect and recover money owed to us
|a) Performance of a contract with you|
b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:|
a) Manage your online account
|a) Necessary to comply with a legal obligation.|
b) Necessary for our legitimate interests (to keep our records updated and to study use of our services).
|Send you information about new services that may be of interest to you||Necessary for our legitimate interests (to develop our products/services and grow our business).|
|Fraud prevention and detection, to prevent security breaches and other crimes.||a) To prevent and detect fraud against you or us (Legitimate Interest)|
b) Necessary to comply with a legal obligation
|To deliver relevant website content and measure or understand the effectiveness of the advertising or content.||Necessary for our legitimate interests (to study how people use our products/services, to develop them, to grow our business and to inform our marketing strategy).|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation).|
b) Necessary to comply with a legal obligation.
|To log your contract history with us and to build a profile about you and your job preferences||Necessary for our legitimate interest to be able to perform our recruitment services and to keep you informed.|
|To use data analytics to improve our website products/services, marketing, client relationships and experiences||Necessary for our legitimate interests (to define our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To carry out ID verification using passport/biometric data; including criminal record checks when required||a) We will obtain your consent for this processing in advance|
|To make suggestions and recommendations to you about services that may be of interest to you||Necessary for our legitimate interests (to develop our products/services and grow our business)|
HOW LONG WE RETAIN YOUR PERSONAL DATA
We will hold Your personal data for 6 years (based upon the average job change timeline being 5 years), unless we are notified that you are deceased, you ask Us to stop processing Your personal data and we have no other, overriding legal basis or requirement for keeping it. We also keep your data for 6 years if you have purchased training services from us, so that we can keep the required financial records for HMRC and to handle any complaints or claims which may arise (though we believe our standard of service will mean this isn’t a concern).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive marketing communications from us if you have requested information from us or received services from us and, in each case, you have not opted out of receiving that marketing.
We will not share your data with third parties without your express consent.
You can ask us to stop sending you marketing messages at any time by contacting us at email@example.com or by clicking on the “Unsubscribe” link in any marketing e-mail you receive from Us.
Where you opt out of receiving these marketing messages, this will not apply to personal data which we process in order to provide our recruitment services on your behalf.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURE OF YOUR PERSONAL DATA
For as long as We have access to your personal data, We may share any of it with any of the following to the extent that they need to have access to Your personal data in order to perform their role:
(1) Anyone within Our organisation which includes, without limitation, Our sales and marketing teams, and our finance team.
(2) Selected third parties who help us to perform our services with you. This includes third parties who help us directly such as our recruitment software companies: Chameleoni and DropBox.
(3) The Governments and authorities of the United Kingdom, and in particular HMRC.
(4) Our IT service providers who provide, maintain, improve, manage, optimise or fix the IT facilities that We use or rely on in our business, including computing devices, computer networks, connectivity, telecommunications, software, our Website.
(5) Our online service providers, who provide marketing and advertising placement services for Us, including providers of search engines, analytics services, behavioural marketing services, and online applications and services including social media.
(6) Any third party company or companies in the event that We go through a business transition, such as a merger, being acquired by another person or company, or selling a portion of Our assets.
(7) With your employer, when you are providing work through an umbrella or personal service company.
(8) With any of our self-employed trainers who also provide our training services.
We reserve the right to disclose Your personal data to other third parties if We have lawful grounds to do so, or are under a legal obligation to disclose or share it with them, or in order to established, exercise or defend Our legal rights, or to protect the rights, property, or safety of the Company. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
For further details on any of the above please contact us at firstname.lastname@example.org.
OUR TRANSFER OF YOUR PERSONAL DATA ABROAD
Your data is held within a secure area of DropBox where only The Industry Club personnel can access. This data is held in the USA, however, DropBox hold all the data security accreditations necessary to secure data.
The European Commission decides, for the purposes of Data Protection Legislation, whether or not states outside the European Economic Area have “adequate” safeguards for personal data.
In the case of the United States, it is not currently considered to provide adequate safeguards, although its Government operates Privacy Shield and members of that scheme are considered to have “adequate” safeguards. DropBox hold a Privacy Shield certificate.
YOUR RIGHTS UNDER THE DATA PROTECTION LEGISLATION:
(1) You have the right to access personal data that We hold about You. Your right of access can be exercised in accordance with the Data Protection Legislation. You can submit a data access request at any time. In order to do this, please contact Us at email@example.com.
(2) If You become aware of any inaccuracies in Your personal data which We process on Your behalf, You have a right to ask us to rectify the inaccuracies. On receiving Your request We will either fulfil it or explain why We have decided not to.
(3) To the extent that (a) We no longer need to use Your personal data (e.g. You no longer wish to receive marketing from Us, ) for purposes described in our Notices, or (b) We rely on Your consent and You have withdrawn it, or (c) You object to our legitimate interests for using Your personal data and no exception applies to permit Us to keep using it, or (d) it is established that We did not have the lawful right to process Your personal data, or (e) the law requires us to erase Your personal data, You may ask us to erase Your personal data. If we erase Your personal data, Your ability to use our services will be affected.
(4) You have the right to ask Us not to process Your personal data for marketing purposes. You may unsubscribe at any time by emailing Us directly at firstname.lastname@example.org.
(5) You have the right to object to Our processing of your personal data to the extent that (a) We use the personal data on grounds of Our legitimate interests and no exception applies to permit us to keep using it, or (b) We use it for direct marketing purposes, or (c) We use it for scientific or historical research purposes or statistical purposes and no exception applies to permit Us to keep using it.
(6) You have the right to ask us to restrict Our processing of your personal data to the extent that (a) You have questioned the accuracy of the personal data and We are still checking its accuracy, (b) it is established that We did not have the lawful right to process the personal data, (c) We no longer need to use Your personal data for the purposes We collected or used it for but You need it to be preserved for the purposes of legal claims, or (d) You have exercised Your right to object to Our use of your personal data and no exception applies to permit us to keep using it.
(7) You have the right to request that We provide to You, or to another data controller on Your behalf, a copy of any of Your personal data which We process using automated means based on your consent, so that You may reuse such personal data for Your own purposes on alternative services.
(8) You have the right not to be subject to automated processing which significantly affects You, unless We need to carry out the automated decision-making to enter into or perform our services with You, or We are authorised by law to use the personal data for automated decision- making, or We have Your explicit consent.
(9) You have the right to complain to the Information Commissioner (http://www.ico.gov.uk/) if You have any concerns in respect of the handling of Your personal data by the Company.
If You would like to exercise any of the above rights, including to withdraw Your consent (where Our processing of Your personal information relies on Your consent), please contact Us at email@example.com.
OUR PROTECTION OF YOUR PERSONAL INFORMATION
We have taken reasonable steps to put in place appropriate security measures to protect Your personal data when it is processed by Us or on our behalf.
YOUR COMMENTS ARE APPRECIATED
If You have any questions or comments regarding the Privacy Notice, You can send Us an email at firstname.lastname@example.org