NM Partners Ltd (trading as Allexo Search)
At Allexo Search we are commited to respecting your privacy and keeping your personal data secure. This notice will explain how we may use personal information we collect before, during and after your working relationship with us.
The General Data Protection Regulation (GDPR) is a new regulation which replaces the Data Protection Regulation. The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
If have any questions about how we might be handling your data, please reach out to our Data Privacy and Protection Team.
Who we are and what we do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We collect the personal data of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent or temporary roles
- Prospective and live client contacts
- Supplier contacts to support our services
- Employees, consultants, temporary workers
Personal Information you give us or we collect about you
This is Information about you that you give us by filling in forms on our site www.allexosearch.com or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site.
The information you give us or we collect about you may include the following
- Your name
- Current company, job title, division
- Notice Period
- The source / origin of your contact with us as a business
- e.g. Our website, Linkedin, Job Boards, referral
- Private and corporate e-mail address
- Phone number
- Skype ID
- Financial information, including salary, day rate, package and benefits
- Compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom (including Passport, Nationality and Visa)
- Curriculum vitae and photograph
- Links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website
- Desired work location
- Employment preferences
Sensitive / Special Categories of data
We may at times be required to collect sensitive personal information called special categories under GDPR. We will only process this information with your explicit consent.
Only if it is necessary in the context of employment law and a policy is in place, or for an assessment of the individual’s working capacity, or to protect the vital interests of the data subject, or the individual themselves made the personal data public, or to establish or defend a legal claim, or in the substantial public interest.
Sensitive information means information relating you your race, ethnic origin, polical opinion, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation.
Where we collect your information
As a candidate if we collect your personal information (and this can include special category data) we will inform you, by sending you this privacy notice, within a maximum of 30 days and make you aware of the source the personal data originates from (see list below)
- Corporate websites
- Personal & professional recommendations or referrals
- Your business card
- Online Job and CV boards
Purposes of the processing and the legal basis for the processing
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
WHAT WE DO
LEGAL BASIS UNDER GDPR FOR PROCESSING
Assist you to find employment, provide you with advice about your employment options, to assist you in achieving your employment objectives and provide you with job opportunities..
Article 6(1)(b) this is necessary for the performance of our contract with you or in order to take steps at your request prior to entering into a contract. Without it we will not be able to assist you in seeking employment.
Article 6(1)(f) – this is necessary for our legitimate interests.
Support and manage our employees and workers
Article 6(1)(b) This is necessary for the performance of our contract with you or in order to take steps at your request prior to entering into a contract. Without it we will not be able to process you in seeking employment.
Article 6(1)(c ) This is necessary for compliance with our legal obligations to which we are subject
To generate commercial business with commercial organisations
Article 6(1)(f) This is necessary for our legitimate interest.
To assist employees and workers to fulfil a potential employment opportunity or to make or assess a reasonable adjustment, or to engage occupational health services or emergency treatment.
Article 9(2)(b) – processing is necessary for the purposes of carrying out the obligations and exercising our specific rights or your rights in the field of employment providing for appropriate safeguards to your fundamental rights and the interests
Article 9(2)(a) where you have given your explicit consent to the processing of your special category data for one or more specified purposes
Or in limited circumstances Article 9(2)(c) processing is necessary to protect your vital interests where you are is physically or legally incapable of giving consent.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidates and client personal data containing historical information as well as current resourcing requirements.
We match your details with job vacancies, to assist us in finding a position that is most suitable for you and to send your personal information (including sensitive personal information) to clients in order to apply for jobs
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other uses we will make of your data
- Use of our website
- To notify you about changes to our service
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer
- To allow you to participate in interactive features of our service, when you choose to do so
- As part of our efforts to keep our site safe and secure
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
Automated decision making
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process
Disclosure of your information inside and outside of the EEA
We will share your personal information with selected third parties including:
- Clients for the purpose of introducing candidates to them
- Candidates for the purpose of arranging interviews and engagements
- Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you
- Subcontractors including email marketing specialists, event organisers, payment and other financial service providers
- credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If NM Partners (Trading as Allexo Search) or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
The lawful basis for the third party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs
- Satisfaction of their contractual obligations to us as our data processor
- For the purpose of a contract in place or in contemplation
- To fulfil their legal obligations
Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. 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 notice.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice [and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
- Our website (www.allexosearch.com) enables you to manage your data and to review whether the details we hold about you are accurate
- Prior to making an introduction we check that we have accurate information about you
- We keep in touch with you so you can let us know of changes to your personal data
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data Includes:
- The nature of the personal data;
- Its perceived accuracy;
- Our legal obligations;
- Whether an interview or placement has been arranged; and
- Our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
We will retain basic information about you for a minimum of 10 years for tax, finanicial, legal obligations or commercial purposes. Subject to any legal requirement, we will delete your information where you tell us that you no longer wish to be registered with our organisation, or 10 years after our last engagement with you.
Our current Data Retention Policy is available upon request.
A Data Security breach could occur where information or data has been processed without appropriate measures being taken to protect the data. Examples of a Data Security breach could be:
- Candidate information being sent electronically to a 3rd party without appropriate authorisation, encryption or password protection
- Non-adherence to Allexo’s ‘Secure Desk’ policy; for example, Customer information being written down and left unattended at any time
A Data Protection breach could occur where data is obtained or viewed by a person that was not authorised to receive it. Some examples of a Data Protection breach could be:
- Loss or theft of data or equipment on which data is stored
- Inappropriate access controls allowing unauthorised use
- Equipment Failure
- Social Engineering offences where information is obtained by a third party by means of deception
Our Data Protection and Privacy Team will maintain a log of data breaches and provide any necessary support in managing and resolving the breach.
You are in complete control and have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights. To:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below)
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
- Request the transfer of your personal information to another party in certain formats, if practicable
- The right of access to your personal data, this is called a Subject Access Request (see below for further details)
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
A Subject Access Request (SAR) should be submitted to email@example.com. No fee will apply once the GDPR comes into force.
If you are dissatisfied with our response you can complain to the Information Commissioner’s Office
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org or by writing to us at
NM Partners Ltd
Unit 111 Vox Studios,
1-45 Durham Street,