WHAT DATA WE COLLECT
When collecting data from you regarding your interest in a position, we need to process certain personal information about you in addition to understand your ambitions, skills and knowledge, this may include:
- Email address
- Phone numbers
- Other contact details
- Education details
- Employment history
- Salary and other remuneration information
- Personal circumstances related to work
- Extra information you choose to tell us about you
- IP address
- What you’re interested in
- Current benefits and obligations
- Health, visa and diversity information – in accordance with laws and requirements
Client related data
If you are a customer of FMC or you are enquiring about becoming one, there is a certain amount of information we need to know about you as a contact, such as:
- Email address
- Phone numbers
Over the course of our relationship with you, we may also hold information relating to:
- Finance team contact details
- Information relating to recruitment needs
- Information relating to company ambitions
- IP address
- What you’re interested in
From our suppliers we will hold a small amount of information to ensure things run smoothly. We need to collect these things to ensure our communication runs smoothly:
- Email address
- Phone numbers
- Bank or payment details
If someone has been referred by another individual to our organisation, we hold a small amount of information about the referred person, held until consent can be gained from the referral and more information can be gathered. We will not hold your information for more than one month without you being advised and receiving our policy.
From time to time, we collect information for market research directly from an individual. Data such as this is stored and can include:
- Views and opinions
- Recruitment statistics and predictions
HOW WE USE YOUR DATA
We are most likely to use your data to find you a new job or understand your position in the market to help you achieve the next step in your career. We may contact you by email, phone, fax or mail. We may also use your job search related information to profile the market and market research. You will be asked for consent when needed for us to use this personal data and where appropriate your data will be anonymised.
At present, all our recruitment activities involve human decision making during the process. Should we ever decide to have automated technologies in the future that make decisions around your application to a job or suitability for a job, we will update this policy to say so.
Client related data
The main reason for us to use the data of a client would be to ensure the relationships runs smoothly. We will use the information you give us as a client to give you a bespoke service and identifying candidates that are right for your organisation. Sometimes we may ask you information for market research, your consent will be gathered and where appropriate your data will be anonymised.
The reason we use the data of a supplier is to ensure the contractual arrangement between us runs smoothly and that it complies with legal requirements.
We use referral information to qualify whether a candidate is right for the job, we my also use the personal data of a referral to contact them regarding recruitment activities that may be of interest to them.
When specified, we may gather marketing research data, this data is used to publish marketing reports and insight that may be of interest to you and your peers. Consent will be taken when gathering marketing data.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We will share your information with prospective employers, once your permission has been given, this is how we use your data primarily. Unless you have opted out of marketing from FMC, we may also profile you and target you via marketing campaigns to promote jobs you may be interested in. In addition to this, if your data is used in a market mapping activity or research by FMC, your data will remain aggregated and anonymous unless we have gained your permission.
Client related data
Your personal data will remain internally at FMC and not shared with third parties, we will only share your information with prospective talent and unless you have opted out of marketing from FMC, we may also profile you and target you via marketing campaigns to promote candidates or news you may be interested in. Occasionally your data may be used in market mapping or research by FMC, your data will remain aggregated and anonymous unless we have gained your permission.
Unless specified otherwise, we may occasionally share your information with third parties such as other service providers and organisations.
Unless specified otherwise, we may share referral information with potential employers, once we have your permission to do so, and we may share it internally.
Consent will be taken when any marketing or market research data is gathered, this may be used in publishing and shared across various social and be platforms. This data is usually aggregated and anonymous unless otherwise specified.
THE LEGAL REASONS WE PROCESS YOUR DATA
Article 6 (1) (f) of the GDPR is the legal reasons relevant to us and why we process and hold your data. Its states that it “is necessary for the purposes of the legitimate interests pursued by (us) or by a third party, except where such interests are overridden by the interest or fundamental rights or freedoms of (you) which require protection of personal data.”
If you are looking for a job, have posted your CV on a job board or professional networking site, or have spoke to us directly about a job, we have shared legitimate interest. We therefore are able process your information and pass this information to the client in charge of your prospective new employment.
Once you have had contact with us and we share legitimate interest, we want to provide you with tailored job recommendations and relevant news in your industry. We therefore think it is reasonable to contact you with this appropriate content. You can request to not be contacted with this type of content at any time.
Aside from this, we may need to use your information to carry out administrative duties like payroll an invoicing where relevant, so your data would continue to be of legitimate interest.
Client related data
To ensure we provide you with the best service possible, we store your personal data and/or the personal data of individuals in your organisations, as well as keeping records of the activity we’ve undertaken with you. This may include written recording of our conversations, meetings, jobs, and placements.
From time to time we ask you to complete market or satisfaction surveys, and we may contact you with marketing materials including articles and news that we think you’ll find interesting and is relevant to your work. You can request to not be contacted with this type of content at any time.
Therefore, as we are striving to provide you with services, we deem this data to be necessary for our legitimate interests.
We use your data to enable you to provide a service to us, which hold legitimate interest. We deem all data such as financial details necessary to enable us to work with you.
Contacting referrals is part of our quality control process here at FMC, we deem this necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.
We may gather insight and knowledge from you to be used as marketing data for reports and news production. You will be asked permission for this information at the time and you will be contacted with the results of the marketing data gathered. All this data is anonymous unless otherwise stated.
HOW WE COLLECT YOUR DATA
Throughout FMC, data is collected through these channels:
- Directly from you, over the phone or via internet or video call
- Directly from you, face to face
- Directly from you, over email, fax or mail communication
- From third party job websites such as Jobsite or Indeed
- From third party social websites such as LinkedIn
- From the FMC website – when a form is completed
- From the FMC website – based on your activity
- From other individuals you know, referring you to us
This data is stored in a secure system and cleansed regularly. At any time, your data can be removed from the FMC system or requested.
To process your data in some circumstances, such as when we are sharing your information with a client, or when you are receiving marketing from us, we are required to ask for your consent. This will be opt-in consent or soft opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is “any feely given, specific, informed and unambiguous indication of the data subjects wishes by which he or she, by statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.”
- You have freely given us consent
- You know what you are consenting to
- You have control over which processing activities you consent to and which you don’t
- You have taken positive and affirmative action in giving us your consent
However, in some cases we can rely on soft opt-in consent. For example, when marketing our services to you or sharing news relating marketing, we are able to provide this as long as you not actively opt-out from these communications.
SAFEGUARDING YOUR DATA
We are committed to ensuring your data is secure, in order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
HOW LONG DO WE KEEP YOUR DATA FOR?
We will keep your data for no longer than you wish us to, it can be deleted upon request. If we have not had meaningful contact with you for a period of 36 months, we will delete your personal data from our systems unless we believe that we should lawfully preserve it (from example, because our obligations to tax authorities or in connection with any anticipated litigation).
When we refer to “meaningful contact”, we mean communication between us (either verbal or written). We will consider it meaningful contact with us if you have submitted your CV to us, communicated with us about potential roles, communicated with us about the potential of working together or clicked through on our marketing communications.
ACCESSING, AMENDING OR TAKING BACK YOUR DATA
You have rights to your data and can get in touch with us at any time at firstname.lastname@example.org or +44 (0) 1522 695 011 or at FMC Global Talent, Fairfax House, 2 Henley Way, Lincoln LN6 3QR.
One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means you retain rights in respect of your data, even once you have given it to us.
We will seek to deal with your data request without undue delay and in accordance with the requirements of any applicable laws. Please note that we will keep record of any communications relating to this request to help us resolve it.
The rights you have to your data include the following:
Right to object
If you do not agree that we are using your data for legitimate interests, you have the right to object. We will respond to your request within 30 days, unless other limited conditions apply.
Right to withdraw consent
Where you have obtained your consent to process your personal data previously, you may withdraw this consent at any time. Just let us know.
Data subject access requests (DSAR)
You have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information. At this point we may ask more information about your request, before complying with you.
Right to erase
You have the right to contact us to erase your information at any time. At the point of receiving one of these requests, we aim to complete the deletion within 30 days of the request. At the point of receiving one of these request, we will confirm with you whether you want to be completed deleted, or whether you’d be happy to archive with minimal information – this will minimise the chances of you being contacted again.
We would be entitled to refuse to comply with your request for one of the following reasons; to exercise the right of freedom for expression and information, to comply with legal obligations or for the performance of public interest task or exercise of official authority, for public health reasons in the public interest, for archival, research or statistical purpose, or to exercise or defend a legal claim.
Right to rectification
You can request that we rectify any inaccurate or incomplete personal data that we hold about you. We will ensure that this information is altered and notify you that it has been complete.
Right to restrict processing
You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing with it unless you give us your consent or when further processing is necessary for either the establishment, exercise or defence of legal claims.
Right of data portability
If you wish, you have the right to transfer your data from us to another data controller. We will help with this, either by directly transferring your data for you, or by providing you with copy in a commonly used machine-readable format.
Right to lodge a complaint with a supervisory authority
You also have the right to lodge a complaint with your local supervisory authority, details of which can be found at the end of this document.
Right to unsubscribe
If your interests or requirements change, you also have the right to unsubscribe from some or all our marketing content, by clicking the unsubscribe link or contacting us at email@example.com.
LINKS TO OTHER WESBITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
CONTROLLING YOUR PERSONAL INFORMATION
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
INTERNATIONAL DATA TRANSFER
FMC provide recruitment services globally and so for us to continue operating in this way, we may have to transfer your data internationally. Your data may be transferred:
- to overseas clients, where you have consented;
- to clients within the UK who may, in turn, transfer your data internationally to other parts of their business, where they have a shared legitimate interest in processing your data.
Your data will always be transferred in a way that is secure. You will always know which prospective employers we are sharing your information with. We will gain your consent before your details are shared with a prospective employer.
DEFENDING LEGAL CLAIMS
It may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9 (2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
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You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please contact:
FMC Global Talent, Fairfax House, 2 Henley Way, Lincoln, LN6 3QR
Phone: +44 (0) 1522 695 011
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
CONTACTING THE LOCAL SUPERVISORY AUTHORITY
The Information Commissioners Office. You can contact them in the following ways:
Phone: 0303 123 1113
Information Commissioner’s Office,