Privacy Policy
This privacy policy applies between you, the User of this Website and 121 Recruitment Consultants Ltd, the owner and provider of this Website. 121 Recruitment Consultants Ltd, takes the privacy of your personal information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website or any services you take from us.
The privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at www.121.uk.com
Please read this privacy policy carefully.
Definitions and interpretation:
In this privacy policy the following definitions are used.
| Data | Collectively all information that you submit to 121 Recruitment Consultants Ltd via the website or any other means, including but not limited to Personal Data. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws: |
| Cookies | a small text file placed on your computer by this website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause/section below (Cookies); |
| Data Protection Laws | any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation; |
| GDPR | the UK General Data Protection Regulation; |
| 121 Recruitment Consultants Ltd,
we or us |
121 Recruitment Consultants Ltd, a company incorporated in England and Wales with registered number 08359864 whose registered office is at 17 Hanover Square, London W1S 1BN; |
| UK and EU Cookie Law | the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018; |
| User or you | any third party who accesses the Website (or otherwise provides any Data to us, and is not either (i) employed by the 121 Recruitment Consultants Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to 121 Recruitment Consultants Ltd and accessing the Website in connection with the provision of such services; and |
| Website | the website that you are currently using, and any sub-domains of this site unless expressly excluded by their own terms and conditions. |
- In this privacy policy, unless the context requires a different interpretation:
- the singular includes the plural and vice versa;
- references to sub-clauses, clauses, schedules or appendices are to sub-clause, clause schedules or appendices of this privacy policy:
- a reference to a person includes firms, companies, government entities, trust and partnerships;
- “including” is understood to mean “including without limitation”
- reference to any statutory provision includes any modification or amendment of it;
- the heading and subheading do not form part of this privacy policy.
- This privacy policy applies only to the actions of 121 Recruitment Consultants Ltd and Users with respect to this Website. It does not extend to any website that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
- For purposes of the applicable Data Protection Laws, 121 Recruitment Consultants Ltd, is the “data controller”. This means that 121 Recruitment Consultants Ltd determines the purposes for which, and the manner in which, your Personal Data is processed.
The privacy policy explains how we collect and use your Personal Data, when obtained directly from you or through the Website
The 121 Recruitment Consultants Ltd is a recruitment business, which provides work-finding services to its clients and work-seekers. The 121 Recruitment Consultants Ltd must process Personal Data (including sensitive Personal Data) so that it can provide these services – in doing so, the 121 Recruitment Consultants Ltd acts as a “data controller”.
You may give your Personal Data to us 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. We 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 this privacy policy. At all times we will comply with current data protection laws.
What constitutes ‘Personal Data’
Personal Data is any information relating to an identifiable person who can be identified (directly or indirectly) by reference to an identifier.
Data Protection – Privacy Policy
In order for us to comply with GDPR (General Data Protection Regulation) legislation, there are six data protection principles that we must follow. The Personal Data that we hold about you must be:
- Processed lawfully, fairly and in a transparent manner
- Processed only for specified, explicit and legitimate purposes that have been clearly explained to you
- Adequate, relevant and limited to what is necessary
- Accurate and kept up to date.
- Kept for no longer than is necessary
- Processed in a way that ensures appropriate security of the data
Contents of Privacy Policy Explained
- Collection and use of personal data
- Purpose of processing and legal basis
- Legitimate Interest
- Statutory/contractual requirement
- Recipients of Data
- Information to be provided when data is not collected directly from the data subject
- Categories of data
- Sources of data
- Data Retention
- Your Rights
- Cookies
- Login files
- Links to external sites
- Sale of the business
- Data Security
- Changes to this privacy statement
- Complaints or queries
- Collection and use of personal data
- Purpose of processing and legal basis
121 Recruitment Consultants Ltd 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. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients. All of which are explained in more detail below.
Candidates
We collect Data in the following ways:
- We collect your personal data from; you and
- Data is collected automatically – see below
Data that is given to us by you
121 Recruitment Consultants Ltd will collect your Data in a number of ways:
When you contact us and use the website
When you contact us by telephone or by post
When you read and respond to our emails/letters
When you elect to receive marketing communications from us;
When you use our services
in each case, in accordance with this privacy policy
Data that is collected automatically
To the extent that you access the Website, we will collect your Data automatically, for example:
We automatically collect some information about your visit to the Website. This information helps us to make improvements to the Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
We will collect your Data automatically via Cookies, in line with cookies settings on your browser. For more information about Cookies and how we use them on the Website see the section below, headed “Cookies”
The types of Personal Data we collect
We currently collect and process the following Personal Data from you, which can be used to identify you, this Personal Data can include but is not limited to, your name, address, contact details, email address, driving licence, passport details, education details, work history. Please refer to the ‘categories of data/data retention’ information below for a more in-depth list of the types of Personal Data that we collect.
How you share your Data with us
You share our data with us by:
- providing us with a hard copy of your CV at interview
- posting us your CV directly or by submitting your CV details onto the website, when applying for a job
- emailing us a copy of your CV directly
- completing a registration/application from
How do we use your Personal Data
Now that we have obtained you Personal Data, we use it in a number of ways. The main reason for doing so, is to find you work seeking opportunities, however, there are other reasons for which we use your data: These include Marketing Activities, Recruitment Activities, Equal Opportunities Monitoring, Internal record keeping and to help us to establish, exercise or defend legal claims.
Who do we share your Personal Data with?
Primarily we share your Personal Data with prospective employers/clients/professional advisors, to find you employment. A more in-depth list of whom we share your Personal Data with is indicated in Recipients of Data section below.
Prospective Candidates
We collect Data about you including your name, contact details, professional history obtained from publically available sources, like Linkedin, Twitter, and other social media sites. This is so we can make contact with you if we feel your skill set matches one of our prospective jobs and that you may be interested in our job opportunities (present and future). We may obtain your contact details from other candidates registered with us or an employer who has recommend we contact you.
How we use your Personal Data
We use your Personal Data to establish whether you could be interested in our work finding services and how we can help you for present and future job opportunities.
Clients
We use your Personal Data
- to fulfil our contractual obligations with you
- to offer and provide to you our recruitment services
- to exercise and defend legal claims
- to maintain our working relationship
- to answer any questions and queries you have
- for direct marketing purposes
Suppliers
We use your Personal Data
- to fulfil our contractual obligations with you
- to exercise and defend legal claims
- to maintain our working relationship
- to answer any questions and queries you have
- for direct marketing purposes
Marketing – Our use of data
For the delivery of direct marketing to you via email, we’ll need your consent, whether via an opt out or soft opt in:
- soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us for more details about a particular service, and we are marketing similar services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting, by for example, checking a tick box that we’ll provide/on application.
- if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
If on registration you have signed and agreed to receive communication from the agency, we may also send you marketing information and news via email/ text. You can opt-out from receiving this marketing information/email and texts, at any time, by contacting us and requesting this, by email – admin@121.uk.com.
We must have a legal basis to process your Personal Data.
The legal bases we rely upon to offer our work-finding services to you are:
Your consent the individual gives his or her consent to the processing of his or her data for a particular purpose;
Where we have a legitimate interest Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data,
To fulfil a contractual obligation that we have processing is necessary in relation to a contract to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract;
To comply with a legal obligation that we have processing is necessary because of a legal obligation that applies to the data controller (except an obligation imposed by a contract);
Protecting – Vital Interests processing is necessary to protect the ‘vital interests’ of the individual or another person (this condition only applies in cases of life or death);
Carrying out a – Public tasks for administering justice, or for exercising statutory, governmental, or other public functions;
- Your Consent – In detail:
On registration with the agency, you will be provided with a consent form to read/complete and sign, which will enable processing for your data for a particular purpose. In certain circumstances we are required to obtain your consent to the processing of your Personal Data.This means:- Consent must be freely given;
- Consent needs to be specific and informed; this means it must specifically cover the following: the controller’s identity – the purpose of the processing – the processing activities – the right to withdraw consent at any time
- Consent should be obvious and require a positive action to opt in. It must be concise and easy to understand and user-friendly.
- When consent is given – you have to know what you are consenting to – this information will be made clear on the consent form, which you will receive on registration
- You will need to take positive and affirmative action in giving us your consent – we can help to provide this action on the consent form, (with a tick box option)
- Explicit consent must involve a specific informed and unambiguous indication of the individual’s wishes. Explicit consent must be expressly confirmed in a clear statement/whether oral or written
We will keep records of the consent that you have given in this way. You have the right to withdraw consent at any time – refer to ‘Your Rights’ section below.
- Legitimate Interest This is where we have a legitimate reason to process your Personal Data provided it is reasonable and does not go against what you would reasonably expect from us. Where we have relied on a legitimate interest to process your Personal Data our legitimate interests is/are as follows:
- Managing our database and keeping work-seeker records up to date;
- Providing work-finding services to you and our clients;
- Contacting you to seek your consent where we need it;
Giving you information about similar products (marketing) or services that you have used from us recently;
- Statutory/Contractual requirement
We have certain legal and contractual requirements to collect Personal Data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) Our clients may also require this Personal Data, and/or we may need your Data to enter into a contract with you. If you do not give us Personal Data we need to collect we may not be able to continue to provide work-finding services to you: therefore we will be unable to complete our contractual requirements with our clients and thus will be unable to process an application or registration further on your behalf to/or find you any work seeker opportunities. - Recipient(s) of Data
We will process your Personal Data and/or sensitive Personal Data with the following recipients:- Clients (whom we may introduce or supply you to), including: public sector UK government departments and private sector clients
- Former employers or individuals whom we may seek references from
- Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to (3rd party screening providers)
- Service providers who perform functions on our behalf (including: technical support functions and IT consultants-carrying out testing and development, business associates, professional advisers-lawyers, auditors, accountants
- Marketing, technology platform suppliers
- Other recruitment agencies in the supply chain /compliance teams
- REC (audit purposes)
- HMRC (tax purposes)
- Insurance Companies
- Credit Checking Agencies
- Education Institutes – Universities, Colleges, Schools
- Information to be provided when Data collected not from the data subject
- Categories of Data: The Company has collected the following Personal Data on you:
Personal Data (not an exhaustive list)- Name, age, sex/gender, address, emergency/contact details, mobile no., email address
- Proof of ID (driving licence and or passport/identity card)
- National insurance no., Social security no., (tax related information)
- Nationality (through right to work check) place of birth, citizenship
- Immigration status (whether you need a work permit)
- Education details, employment history,
- Financial Information, (where we need to carry our financial background checks),
- Any other extra information that you choose to tell us
Sensitive Personal Data (not an exhaustive list)
- Health information including whether you have a disability
- Criminal conviction – DBS background checks
- Diversity, Ethnicity and Race
- Source of the Personal Data: We source your Personal Data/Sensitive Personal Data
(not an exhaustive list)- From – Jobs boards, Total Jobs, Indeed, CV Library, LinkedIn and Twitter
- Former employers
- Referees whose details you previously provided to us
- Software providers who we use to support our services including: http, SAP, macOS,
- Cookies listed in section 5
- Social media, professional networking
- Categories of Data: The Company has collected the following Personal Data on you:
- Data Retention – How long do we keep your Personal Data?
We will retain your Personal Data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different Data for different periods of time. For example, 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. This is currently 3 to 6 years.Where we have obtained your consent to process your Personal Data and/or sensitive Personal Data we will do so in line with our data retention policy. Upon expiry of that period we will seek further consent from you. Where consent is not granted we will cease to process your Personal Data/and sensitive Personal Data.If we have been unable to assist you with employment within a year of your first enquiry with us, we will contact you to ask if you would like us to remove your Personal Data/sensitive Personal Data from our database (through means of data cleanse) at which stage, if instructed by you, by email, we will remove all of your details and personal information from our database. - Your Rights – Data Protection
Please be aware that you have the following data protection rights:- The right to be informed about the Personal Data we process on you;
- The right of access to the Personal Data we process 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 Personal 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.
You have the right to withdraw consent at any time by contacting the Operations Manager, responsible for Data Protection at 121 Recruitment Consultants Ltd. Please email admin@121.uk.com and address the request to Surita Dadral. Please note; that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
If you believe that any of your data that we process is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of Data we process for you, access your Personal Data or exercise any of the other rights listed above.
- Cookies
What’s a cookie?“Cookies” are small pieces of information, that are stored on your computers hard-drive, normally consisting of just letters and numbers, which online services provide, when users visit them. Software on the user’s device (for example a web browser) can store Cookies and send them back to the website next time they visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.Cookies are used by nearly all websites and do not harm your system. If you do not accept the Cookies on the site, this may restrict areas of use of your visit to the website. Cookies are a specific technology that store information between website visits. They are used in numerous ways, such as: supporting users to log in to a website; analysing traffic to a website; or tracking users’ browsing behaviour.How do we use Cookies? We use Cookies to do two things:
They allow us to track the use of our website to recognise a User’s device. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Without Cookies, or some other similar method, websites would have no way to ‘remember’ anything about visitors, such as how many items are in a shopping basket or whether they are logged in.To help us share/advertise jobs with you that we think may match your skillsetTypes of Cookies – Cookies are either ‘session’ cookies or ‘persistent’ cookies:
Cookies that expire at the end of a browser session (normally when a user exits their browser) are called ‘session cookies’. Cookies that can be stored for longer are called ‘persistent cookies’. PECR (Privacy & Electronic Communications Regulations) applies to both types.Session cookies allow websites to recognise and link the actions for a user during a browsing session. They may be used for a variety of purposes such as remembering what user has put in their shopping basket as they browse around a site. Sessions cookies are only stored on your computer during your web session and are automatically deleted when you close the browser.
Cookies can also be used for security purposes, such as when a user logs in to internet banking or their webmail. These session cookies expire after a session ends, so would not be stored beyond this. For this reason session cookies may sometimes be considered less privacy-intrusive than persistent cookies.
Persistent cookies are stored on a user’s device in-between sessions. They can allow the preferences or actions of the user across a site (or across different websites) to be remembered.
Persistent cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising. The length of time between a cookie being set and expiry is set by the website operator. A user can also delete previously set persistent cookies manually or configure the browser settings to delete cookies at a set interval.
What are ‘first-party’ and ‘third-party’ cookies?
Whether a cookie is ‘first’ or ‘third’ party refers to the website or domain placing the cookie.
First-party cookies are set directly by the website the user is visiting, i.e. the URL displayed in the browser’s address bar.
Third-party cookies are set by a domain other than the one the user is visiting. This typically occurs when the website incorporates elements from other sites, such as images, social media plugins or advertising. When the browser or other software fetches these elements from the other sites, they can set cookies as well.
Cookies can be categorised as:
Strictly required cookies: these Cookies are essential to enable you to use the Website effectively, when applying for a job and therefore cannot be turned off. Without these Cookies, the services available to you on our Website cannot be provided. These Cookies do not gather information about you that could be sued for marketing or where you have been on the internet.
Functionality cookies: These Cookies enable us to monitor and improve the performance of our Website. They also allow us to recognise what parts of the site are mostly visited.
Advertisement cookies: These Cookies help us to advertise details of potential job opportunities that we think may be of interest to you. These Cookies are persistent for as long as you are registered with us, and therefore means that you may see similar jobs opportunities/adverts, that you have previously browsed on our Website.All Cookies used by this Website are used in accordance with the current UK and EK Cookie law.
- Log Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
- Links to external websites
Our Website may contain links to other external websites. Please be aware that 121 Recruitment Consultants Ltd is not responsible for the privacy practices of such other sites. When you leave our Website we encourage you to read the privacy statements of each and every other website that collects personally identifiable information. This privacy statement applies solely to information collected by our Website.
- Sale of business
If our business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
- Data Security
We take every precaution to protect our Users’ information. When sharing Personal Data, where necessary, files are encrypted, and password protected, with firewall and fire-vault and browser certificates.Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information and the Data is always stored securely with access via passwords.We use all reasonable efforts to safeguard your Personal Data. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Personal Data which is transferred from you or to you via email/ the Internet. If you have any questions about the security of our website, you can email Balvir Dadral/Director on admin@121.uk.com
- Changes to this privacy policy
We will update this privacy policy from time to time. We will post any changes on the policy with revision dates. If we make any material changes, we will notify you. We do encourage Website users to regularly check for any changes and updates made to the privacy policy.
- Complaints or queries – How to make a complaint
If you wish to complain about this privacy notice or any of the procedures set out in it, then please contact: Surita Dadral (DPO) at 121 Recuitment Consultants Limited. Email: sdadral@121.uk, or contact us on 0203 356 4949. We will respond to your complaint within 5 working days of receiving it.You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/. The ICO’s address is: Information Commissioners Office, Wycliffe House, Water Lane, Wimslow, Cheshire, SK9 5AF, 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.