Annex A – Data Protection

Annex A – Data protection
In this Annex we explain how Egerton Stephens Partners Limited manages your personal data.

1. Collection and use of personal data

a. Purpose of processing and legal basis
Egerton Stephens Partners Limited 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.

In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

The legal bases we rely upon to offer these services to you are:

• Your consent
• Where we have a legitimate interest
• To comply with a legal obligation that we have
• To fulfil a contractual obligation that we have with you

b. Legitimate interest
This is where Egerton Stephens Partners Limited has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where Egerton Stephens Partners Limited has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• Finding you employment be it temporary, contract or permanent

c. Recipient/s of data
Egerton Stephens Partners Limited will process your personal data and/or sensitive personal data with the following recipients:
• Clients that we introduce or supply individuals to
• Candidates’ former or prospective new employers that we obtain or provide references to
• The Recruitment and Employment Confederation (and any other trade body that you are a member of who may have access to your candidates’ data)
• Any other third parties who carry out audits to ensure we run our business correctly or line with
• Payroll service provider who manages our payroll on our behalf
• Our Invoice factoring company
• Our IT and CRM providers
• Any public information sources and third party organisations that we may use to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS), National College for Teaching and Leadership (NCTL), Nursing and Midwifery Council (NMC), General Medical Council (GMC), DVLA, credit reference agencies
• Government, law enforcement agencies and other regulators e.g the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs), GLAA,
• Trade unions;
• Any other organisations an individual asks you to share their data with

d. Statutory/contractual requirement
Your personal data is required by law and a contractual requirement (e.g. our client may require this personal data), and a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
• If we are unable to do all of these checks we may not be able to introduce or supply a work seeker to a client

Egerton Stephens Partners Limited will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

2. Data Retention
Egerton Stephens Partners Limited 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.

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.

Where Egerton Stephens Partners Limited has obtained your consent to process your personal and sensitive personal data we will do so in line with our retention policy (a copy of which is attached). Upon expiry of that period Egerton Stephens Partners Limited will seek further consent from you. Where consent is not granted Egerton Stephens Partners Limited will cease to process your personal data and sensitive personal data.

3. Your rights
Please be aware that you have the following data protection rights:

• The right to be informed about the personal data Egerton Stephens Partners Limited processes on you;
• The right of access to the personal data Egerton Stephens Partners Limited 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 consent at any time.

Where you have consented to Egerton Stephens Partners Limited processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Natasha Simkins at Natasha@egertonstephens.com

There may be circumstances where Egerton Stephens Partners Limited will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.

If you believe that any of your data that Egerton Stephens Partners Limited processes 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.


4. Complaints or Queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Natasha Simkins at Natasha@egertonstephens.com
You also have the right to raise concerns with Information Commissioner’s Office 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.