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GDPR Privacy Policy

10 May 2018

Create + Adapt are committed to:

Transparency

We ensure you have the right to view, amend, or delete any information we hold on your behalf. We ensure that consent is given during the sign up process for all that use our service.

Accountability

We are accountable for our practices and will have privacy policies that explain how we think about privacy and data protection, get feedback from experts and adapt as needed.

Accessibility

We have full awareness of where any of your data is being help and when outside the EU, ensuring compliance is in place.

Security

Only those who require access to your data are able to and we have the highest level of protection against unauthorised access.

Communication

Our Data Protection Officer is on hand should you have any concerns or issues, they can be contacted at dpo@createandadapt.com

This Privacy Notice details they way in which Create + Adapt collect, handle and process personal data in compliance with GDPR.

Create + Adapt Limited of 8b Greenway Farm, Bristol, BS30 5RL is the Data Controller.

Data protection and privacy is central to Create + Adapt. We comply with current EU data protection law and fully commit to achieving compliance with the General Data Protection Regulations (“GDPR”) from it’s effective date 25th May, 2018. Create + Adapt is a talent acquisition and employer branding agency, operating in the UK.

1. How we collect information

1.a. Create + Adapt receive your personal data when you apply directly for an advertised role via our website; when you respond to a job post placed by Create + Adapt on a job board on behalf of a third party client.

When you apply directly to a job advertised by Create + Adapt you must consent to us collecting and storing your personal information. You will not be able to submit your enquiry or details to Create + Adapt without consenting to us storing your personal data. You will also be consenting to share your information with the client for which the advert is provided.

Information you provide to us which is collected and processed for the sole purpose of finding you suitable employment is as follows:

  • Your name
  • Your address
  • Your email address
  • Your telephone number
  • CV/Work history
  • Your preferences relating to employment (role types, geographical areas, salary)
  • Any other employment related information you provide (e.g. education, training)
  • A log of our communications with you via email and telephone.

This information facilitates our ability to support your job search and to provide a basis for recommendation when shortlisting candidates for a particular role. By explicitly providing consent when you register with Create + Adapt you are providing permission for our storage of this information. Create + Adapt will never share personal information with a third party without your explicit consent.

1.b. Information provided by individual who have worked for Create + Adapt previously, or may work for us is as follows:

  • Passport, permits and visas (if applicable)
  • Date of birth
  • National Insurance Number
  • Details of job offer
  • Reference details from previous employers
  • Financial information (including payroll details and terms, HMRC data, pension scheme details, statutory payments etc.)

Due to the nature of recruitment, a significant number of candidates reconnect with our organisation periodically. It is not uncommon for this to occur years after we have placed them in a role. For this reason, your consent includes explicit consent to retain your personal details until such time as you wish us to delete your records from our database or refrain from further engagement.

2. How we process + store information

This following explains how we process personal data received into our organisation. In order to provide our services to you as an employment agency to find you suitable work and/or candidates for work.

The information collected in Section 1.a. will be used in the following ways:

  • To match you with job vacancies to assist in finding the right position of employment.
  • To put forward your details to our clients for you to be considered for vacancies.
  • To place you with our clients and prospective employers
  • To keep you informed of available opportunities as they arise
  • To keep you informed of the services offered by us

All information collected in Section 1.a. of which you have provided to us is stored on our secure third party applicant tracking system, Recruitee, which works in compliance with GDPR regulations. Visibility of such data will be restricted to employees within Create + Adapt, and the specific client to which you applied to work for.

If you do not consent to Create + Adapt storing your personal data and sharing with the specific client to which you applied to work for, please do not submit your Curriculum Vitae for any roles advertised on our website. If your information is currently stored with us, please request deletion as per the parameters set our in Section 3 below. We are unable to process your application without the store your personal information.

The information collected in Section 1.b. will be used in the following ways:

  • To establish that you have the right to work
  • To put in place contractual arrangements and documentation once a role has been secured
  • To pay you if employment is secured

All information collected in Section 1.b. of which you have provided to us is stored on our secure third party human resources software, CharlieHR, which works in compliance with GDPR regulations. Access to this data is restricted to select members within Create + Adapt.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

3. Disclosure of your information

The information collected in Section 1.a. will be visible to Create + Adapt our select clients.  Such employers and clients will usually be located inside the European Economic Area (EEA) but may be outside of the EEA.  Personal data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection or the appropriate safeguards are in place for your rights and freedoms.  Before such a transfer takes place outside of the EEA, we will provide you with further information concerning this.

The information collected in Section 1.b. may be shared with other trusted third parties such as: HM Revenue and Customs, pension scheme providers, legal advisors and other companies for the purpose of undertaking pre engagement checks for the role or for paying you.

4. Data retention

If you are a candidate or job seeker, we will keep your information for 24 months. This is to ensure that we maintain up to date records of your employment activity. We may on occasion contact candidates stored in our database who are not actively looking for a new role. When you apply for a job using our website you will be asked to tick a box indicating that you consent to us storing the personal data you have provided. By providing consent to our storage of your personal data you are also providing consent to us contacting you if we receive details of a role which specifically matches your career aspirations. We will only do this where you, the potential candidate, meet a detailed brief provided by one of our clients, and where you have provided explicit consent to us storing and using your data. Before this term has ceased, we reserve the right to contact you to regain consent.

If you are an employee of Create + Adapt, we will keep your information until your contract ceases.

5. Legal basis for information processing

We will rely on your consent to process the information noted in Section 1 which is collected at the outset of the recruitment process.

Information and documentation to establish your right to work is processed by us as we are legally obliged to do so.

Information in relation to criminal record checks, which are relevant for some roles, will be processed on the basis that it is necessary for us to comply with the law or consent will be obtained, if required.

Once a position has been found for you, we will process your personal data, including financial information, for the purpose of you entering into a contract to fulfil your role and to enable us to pay you, depending on the specific contractual arrangements and circumstances. For the purposes of paying you, where relevant, we are legally obliged to provide information to HMRC.

Once a placement has been secured, we may also process your data on the basis of our legitimate interests i.e. for administrative purposes.

6. Individual Rights

6.a. Right to access

In line with the stipulations of the GDPR, you have the right to ask for access to your personal information. Once Create + Adapt have verified your identity we will provide the information you requested within 72 hours.

If Create + Adapt receive a request for access to personal information we will verify your identify before releasing your personal data to you. We will not release information to any third party.

If you would like to make a request for access to your personal information please contact: dpo@createandadapt.com

6.b. Right to rectification

In the unlikely event you find personal data stored about you by Create + Adapt is inaccurate, you must advise us immediately. We will amend your personal registration within two weeks.

It is likely that over time your employment history will require updating as you transition to new roles or receive promotion. Create + Adapt undertake to update your details within two weeks of receiving an updated Curriculum Vitae.

6.c. Right to erasure

You have the right to withdraw your consent. Upon receipt of a request to delete an individual’s personal registration, Create + Adapt will ensure that your personal record is deleted within 72 hours.

In the event that you wish to be erased from our database you should contact dpo@createandadapt.com. Please make it clear that you wish to be erased, rather than simply marked as no longer job seeking.

6.d. Right to complain

If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to Information Commissioners Office (ICO) at https:\\ico.org.uk\concerns\.

6.e. Right to restriction of processing

You may request that we suspend your data being processed in our database. Once Create + Adapt have verified your identity we will provide the information you requested within 72 hours.

If you would like to make a request for restriction of processing your personal information please contact: dpo@createandadapt.com

6.f. Right to data portability

You may request that we export all of your data from our database. Once Create + Adapt have verified your identity we will provide the information you requested within 72 hours.

If you would like to make this request please contact: dpo@createandadapt.com

6.g. Right to object

You may request that stop processing your data indefinitely. Once Create + Adapt have verified your identity we will action your request within 72 hours.

If you would like to make this request please contact: dpo@createandadapt.com

7. Notification of Breach

We are aware of our responsibility as a recruiter to protect your information and to only share details with third parties upon receipt of your consent. All of our systems are protected and candidate data encrypted, only Create + Adapt staff and client with which the information is shared have access to the personal information stored in your application.

In the unlikely event that our computer systems are compromised and there is a potential loss of confidentiality we will report this breach to you and the Information Commissioners Office (ICO). In the unlikely event that personal data is taken or exposed from Create + Adapt records without our consent, we will provide reports surrounding that exposure within 72 hours of being notified of such an event and take any action necessary to restore security of your personal data.

8. Emails + other communications

If you are a customer of Create + Adapt, we may send you emails with information about our products and services, or other information that may interest you. E-mails will only be sent based on opt-in, unless you register for Create + Adapt services. If you are registered, you may receive emails about other services or to articles and advice to help you to become a successful user of our services. You can contact us by e-mail to opt-out of our e-mails or use the unsubscribe links provided in the e-mail communications that we send you.

Communications between you and Create + Adapt such as chats, emails, phone conversations and private messages may be stored to improve our communications and for future reference.

9. Cookies

Cookies are a feature of web browser software that allow web servers to recognise the computer used to access a Site. They are small pieces of data that we transfer to your computer’s hard drive to enable our systems to recognise your browser, simplify subsequent interactions with our Site and streamline your use of the site. Find out more about our cookie policy here.

10. Changes to our privacy policy

Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this privacy policy. If you have any questions or concerns, please email us at dpo@createandadapt.com