Privacy Notice (GDPR 2018)

Columbus Consulting Ltd

Columbus Consulting Ltd is a UK registered recruitment business, operating globally from offices in Petersfield, Hampshire. We provide work-finding and recruitment solutions in the fields of Sales, Marketing, HR, Finance and Operations.

This Privacy Policy has been drawn up in reference to the General Data Protection Regulation (GDPR) in the interests of providing you with transparent information about the personal data we collect and process.

Columbus Consulting is a Registered Member of the Information Commissioner's Office (IOC)

Introduction

Columbus Consulting Ltd (‘we’; ‘us’; ‘our’) take your privacy very seriously and are committed to protecting the personal information that we collect. We will take appropriate care to keep your information secure and to prevent any unauthorised access or use of it. We implement various security measures to maintain appropriate controls over the processing and transfer of personal data.

Columbus Consulting Ltd look to comply with best practice and local privacy legislation in all jurisdictions in which we operate. The application of this Privacy Policy may be subject to minor amendments in accordance with law in jurisdictions outside of the UK.

Columbus Consulting Ltd's Privacy Policy will be reviewed from time to time in order to take into account any changes to legislation and our operations/working practices. Any information we hold will be governed by the most current version of Columbus Consulting Ltd's Privacy Policy.

This Privacy Policy documents how we collect personal information and data, how we process it and how you can manage it.

How is personal data collected?

Columbus Consulting Ltd collect personal data in a number of ways. Most commonly these include:

• Registration with Columbus Consulting Ltd as a candidate for employment
• Contact from an employer to whom recruitment services are provided.
• Prospective future candidates for employment or employers whose data is gleaned from widely available sources (such as Linked In).
• When invited to join any networking group that Columbus Consulting Ltd runs.

What personal data is collected?

The type of personal data Columbus Consulting Ltd collect about you will depend on the circumstances in which that data is collected.

The standard personal data Columbus Consulting Ltd collect and store is: your name, your employer, your job title, and your contact details (e.g. email address, telephone number).

Additional data is collected if you have registered with Columbus Consulting Ltd as a candidate for employment, whether currently or in the past. Such data is likely to include a copy of your CV, salary details and expectations, right to work documents, details of applications, recruitment history etc.

Collecting and processing sensitive personal data

Sensitive personal data is data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Columbus Consulting Ltd do not typically collect or store sensitive personal data. However, in some recruitment assignments, our clients may request us to collect and process sensitive personal data from prospective applicants. In that event, we will contact you to ask for your explicit consent for this sensitive personal data to be collected and processed. You may refuse to provide any of the sensitive personal information we request.

Legal basis for processing data and the purpose of processing data

Columbus Consulting Ltd have a legitimate interest for processing personal data, given that it is necessary to process personal data in order to provide our services to you. As long as your data protection rights are not infringed, Columbus Consulting Ltd are allowed to process your data when it is in the interests of the business to do so.

The precise purpose of processing personal data will depend on the circumstances in which tholumbus Consulting Ltd's data is collected.

ColumbusConsulting Ltd will only process your personal data for the reason for which you provided it or for reasons that are directly related to this reason. For example, when you register as job seeker with us, we will use your personal data to assess your skills and experience for employment opportunities, to contact you about suitable roles, to provide you with career guidance, and to put you forward for positions when you give us your consent to do so.

Similarly, when we collect personal data from an employer, we will collect and process the personal data necessary to provide recruitment services to you; to discuss roles with potential candidates and to submit applicants to the prospective employer

Legitimate interest cannot be used as a lawful basis for collecting and processing sensitive personal data, so in the event that our clients request us to collect and process sensitive personal data, we will contact you to ask for your explicit consent for this sensitive personal data to be collected and processed.

In very rare circumstances, we may have a legal obligation to process personal data, for example to law enforcement authorities or to prevent a serious threat to public safety.

Statutory/contractual requirement

Your personal data is not required as part of a statutory and/or contractual requirement, or a requirement necessary to enter into a contract.

Use of personal data for Direct marketing

When we collect personal data from you, we welcome the opportunity to share with you market intelligence in the form of Newsletters, Market Reports, Salary Surveys. We will seek your consent to receive such communications, and when you provide us with this consent, this is knowingly and freely given, informed, clear and specific. You may withdraw your consent from receiving such communications at any time by using the facility to ‘unsubscribe’ included in the email or communication concerned.

Who can access the personal data we collect?

In order to provide our services to you, your personal data will typically be accessible by other employees of Columbus Consulting Ltd as well as the contact by whom the data was originally collected.

Your personal data may also be accessible by third parties who perform functions on our behalf, such as Columbus Consulting Ltd’s IT service providers.

Disclosure of personal data to third parties

Personal data is disclosed to other companies (‘third parties’) depending on the reason for which that personal data is primarily held, or for a related reason. This will be for the reason for which you provided it to us; for example when registered as a job seeker with us, in order to provide your data to a prospective employer once you have confirmed that you would like to apply to an available position or where you have otherwise agreed we may disclose it.

In the event of you being registered as a job seeker with Columbus Consulting Ltd, and asking us to make an application outside of the country from which you are applying, your personal data will be sent to employers in that country. Please be aware that the degree of protection of your personal data in a different country may not be the same as in your country of residence.

Safeguarding and Storage of personal data

All personal data is stored on secure cloud-based servers, and every endeavour is made to have in place sufficient technical and organisational measures to safeguard personal data. We cannot however guarantee that loss, alteration or misuse of data will not take place, despite the security measures we have in place to minimise the likelihood of this eventuality.

Our website and internet based transfers

Using the internet to collect and process data involves the transmission of data on an international basis, given the internet is a global environment. There are risks involved in transmitting data in this way. For instance, by communicating with Columbus Consulting Ltd electronically via our website (www.Columbus Consulting Ltd.co.uk), social networking websites (e.g. Linked In), via job boards or via other websites where we advertise our services, we are unable to guarantee that the personal data you submit will not be intercepted when submitted. External websites operated by other companies will be subject to that company’s privacy practices over which Columbus Consulting Ltd has no control. Columbus Consulting Ltd cannot guarantee the privacy practices of any third party websites.

Data retention

Columbus Consulting Ltd will retain your personal data only for as long as is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as a data controller. Different laws require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Business Regulations 2003, require us to keep work-seeker and hirer records for at least one year from (a) the date of their creation or b) after the date on which we last provide work-finding services.

Columbus Consulting Ltd will typically retain personal data for up to ten years from the date of last contact, unless it is deemed necessary to retain such personal data for longer.

Where we have sought explicit consent for the collection and processing of sensitive personal data, this will only be stored and processed for the defined period of time that you have given your explicit consent for such to be stored and processed.

Your rights

Please be aware that you have the following data protection rights: the right to be informed about the personal data Columbus Consulting Ltd processes on you; the right of access to the personal data Columbus Consulting Ltd processes on you; the right to rectification of your personal data; the right to erasure of your personal data in certain circumstances; the right to restrict processing of your personal data; the right to data portability in certain circumstances; the right to object to the processing of your personal data that was based on a public or legitimate interest; the right not to be subjected to automated decision making and profiling; and the right to withdraw any given consent at any time.

You may contact Columbus Consulting Ltd to seek access to, rectify, and/or request deletion of the personal data we hold on you. We will require that you provide suitable identification.

To make a request to access your personal information, please email us with your request and provide verification of your identity. We will provide this information within 30 days, excepting any information that would interfere with the privacy rights and confidentiality of other individuals or companies.

Your co-operation in helping us store accurate personal data for you is very valuable to us. Please email us to rectify any personal data we hold on file you, for example change of name, address details, or to provide us with an up-to-date CV.

Should you wish for your file to be deleted, we will process this where possible, but please be aware that there may be occasions where we may not be required to do so, particularly where your file also includes financial/employment records that we need to keep for periods up to six years.

Should you wish to access, rectify or delete the personal data we hold, please email Columbus Consulting Ltd at toby@columbusconsulting.co.uk.

How to make a complaint

If you believe this policy has been breached in any way, please write to or email Columbus Consulting Ltd, verifying your identity, and setting out in as much as detail as possible the detail of the personal data affected, and the reason for and circumstances of your complaint. We will provide a written response within 30 days after concluding an internal investigation. We may contact you should we need any additional information.

You also have the right to raise any concerns with the Information Commissioner’s Office in the UK on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.

If you need to discuss directly, please contact toby@columbusconsulting.co.uk