Privacy Policy

OVERVIEW

Spectrum’s business has been built on trust: between us and our candidates, clients, contacts, suppliers, employees, associates, and partners.

We will treat all your personal information as private and confidential, except where we are required, by law, to disclose it.

We will use your information for the purposes of delivering our company’s services to you, and for the purposes of communicating with you.

We will never share your details with any 3rd parties, without your permission. If you have sent us a CV, it will never be submitted to a client without your approval.

You may request to see copies of the records we hold for you, or to be removed from our database or mailing lists, at any time you choose.

We fully comply with the General Data Protection Regulation (GDPR).

For further information please contact Spectrum at response@spectrum-ehcs.com

INTRODUCTION

This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates, or you are visiting our website.

It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers and other people whom we may contact in order to find out more about our Candidates.

We aim for our Privacy Policy to be compliant with all applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”).

You can get in touch with us:

  • to access, amend or take back the personal data that you have given to us;
  • if you suspect any misuse or loss of or unauthorised access to your personal information;
  • to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);
  • with any comments or suggestions concerning this Privacy Policy.

The company responsible for your personal data (“Spectrum” or “us”) is:
Spectrum-EHCS Limited
15 Stratton Street
Mayfair
London W1J 8LQ
United Kingdom

You can send an email to: response@spectrum-ehcs.com

Alternatively, you can click the unsubscribe link in any marketing e-mail we send to you.

In the UK, your local supervisory authority is:
The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Phone: 0303 123 1113
Email: casework@ico.org.uk

Any amendments to Spectrum’s Privacy Policy will be published here.

DATA SOURCES

Spectrum handles data from various sources:

CANDIDATES (including prospect Candidates):

In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, age, contact details, education details, employment history, etc. Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health, diversity information or details of any criminal convictions.

There are two main ways in which we collect your personal data:

  • Directly from you; and
  • From third parties (e.g. our Candidates) and other limited sources (e.g. online and offline media).

How do we use your personal data?

The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we may also use your personal data for things like marketing and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.

Who do we share your personal data with?

Primarily we will share your information with prospective employers to increase your chances of securing the job you want. We may also share your information with associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.

We may also share your information with individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies.

NOTE – We will never share your details with any 3rd parties, without your permission. If you have sent us a CV, it will never be submitted to a client without your approval.

What kind of personal information do we collect?

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests:

  • Name;
  • Age/date of birth;
  • Birth number;
  • Sex/gender;
  • Photograph;
  • Marital status;
  • Contact details;
  • Education details;
  • Employment history;
  • Referee details;
  • Immigration status (whether you need a work permit);
  • Nationality/citizenship/place of birth;
  • A copy of your driving licence and/or passport/identity card;
  • Financial information (where we need to carry out financial background checks);
  • National Insurance number (or equivalent in your country) and any other tax-related information;
  • Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
  • Details of any criminal convictions if this is required for a role that you are interested in applying for;
  • Details about your current remuneration, pensions and benefits arrangements;
  • Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;
  • Results of the Business-Focused Inventory of Personality (BIP) Assessment which identifies both work style and motivation traits, matched against the required competencies of a role;
  • Post mandate feedback survey data;
  • Extra information that you choose to tell us;
  • Extra information that your referees choose to tell us about you;
  • Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites;
  • IP address;
  • The dates, times and frequency with which you access our services; and
  • CCTV footage if you attend our premises.

Please note that the above list of categories of personal data we may collect is not exhaustive.

How do we collect your personal data?

We collect Candidate personal data in three primary ways:

  • 1. Personal data you give to us

Spectrum needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities.

There are numerous ways you can share your information with us. These may include emailing your CV to Spectrum or being interviewed by one of our consultants.

  • 2. Personal data we receive from other sources

We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:

  • Your referees may disclose personal information about you;
  • Our Clients may share personal information about you with us;
  • We may obtain information about you from searching for potential Candidate from third party sources, such as LinkedIn and other job sites; and
  • If you ‘like’ our page on Google+ or ‘follow’ us on Twitter we will receive your personal information from those sites..
  •  3. Personal data we collect automatically

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us

How do we use your personal data?

We generally use Candidate data in four ways:

  • 1. Recruitment Activities

Our main area of work is recruitment – connecting the right Candidates with the right jobs. We’ve listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

  • Collecting your data from you and other sources, such as LinkedIn;
  • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
  • Providing you with our recruitment services and to facilitate the recruitment process;
  • Assessing data about you against vacancies which we think may be suitable for you;
  • Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;
  • Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
  • Carrying out our obligations arising from any contracts entered into between us;
  • Carrying out our obligations arising from any contracts entered into between Spectrum and third parties in relation to your recruitment;
  • Carrying out post mandate feedback surveys;
  • Verifying details you have provided, using third party resources (such as BIP tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
  • Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and
  • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object.

  • 2. Marketing Activities

We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:

  • enable us to develop and market other products and services;
  • market our full range of services to you;
  • send you details of reports, networking and client events, and general information about the industry sectors which we think might be of interest to you; and
  • display promotional excerpts from your details on Spectrum’s website and social media channels as a success story (only where we have obtained your express consent to do so).

We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in.

Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.

All our marketing is based on what we think will serve our Clients and Candidates best, but we know we won’t always get it right for everyone. If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time.

  • 3. Equal opportunities monitoring and other sensitive personal data

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of “diversity information”. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Where appropriate and in accordance with local laws and requirements, we’ll use this information on an anonymised basis to monitor our compliance with our equal opportunities policy. We may also disclose this (suitably anonymised where relevant) data to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.

This information is what is called ‘sensitive’ personal information and slightly stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We’ll ask for your consent by offering you an opt-in. This means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.

We may collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your explicit consent.  If you are not happy about this, you have the right to withdraw your consent at any time.

  • 4. To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

CLIENTS (including prospect Clients):

If you are a Client of Spectrum, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as finding Candidates who are the right fit for your organisation or notifying you of content published by Spectrum which is likely to be relevant and useful to you.

There are two main ways in which we collect your personal data:

  • Directly from you; and
  • From third parties (e.g. our Candidates) and other limited sources (e.g. online and offline media).

How do we use your personal data?

The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. This may involve identifying Candidates who we think will be the right fit for you or your organisation. The more information we have, the more personalised our service.

Who do we share your personal data with?

We will share your data primarily to ensure that we provide you with a suitable pool of Candidates. We may also share your information with associated third parties such as our service providers to help us meet these aims.

NOTE – We will never share your details with any 3rd parties, without your permission.

What kind of personal information do we collect?

The data we collect about Clients is very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements. If we need any additional personal data for any reason, we will let you know.

How do we collect your personal data?

We collect Client personal data in three ways:

  • 1. Personal data that we receive directly from you

We both share the same goal – to make sure that you have the best staff for your organisation. We will receive data directly from you in two ways:

  • Where you contact us proactively, usually by phone or email; and/or
  • Where we contact you, either by phone or email, or through our consultants’ business development activities more generally..
  • 2. Personal data we receive from other sources

Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:

  • From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
  • From delegate lists at relevant events; and
  • From other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them)..
  • 3. Personal data we collect via our website

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.

How do we use your personal data?

We generally use Client information in three ways:

  •  1. Recruitment Activities

Obviously, our main area of work is recruitment, providing you with Candidates. These are the various ways in which we use your data in order to facilitate this.

  • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities;
  • Keeping records of our conversations and meetings, so that we can provide targeted services to you;
  • Undertaking post mandate feedback surveys; and
  • Processing your data for the purpose of targeting appropriate marketing campaigns.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object.

  • 2. Marketing Activities

Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.

If you are not happy about this, you have the right to opt out of receiving marketing materials from us.

  • 3. To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

SUPPLIER DATA (including prospect Suppliers):

We collect your personal data during the course of our work with you. We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).

How do we use your personal data?   

The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.

Who do we share your personal data with?

Unless you specify otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.

What kind of personal information do we collect?

We don’t collect much data about Suppliers – we simply need to make sure that our relationship runs smoothly. We’ll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements.

How do we use your personal data?

We realise that you’re probably busy, and don’t want us to be contacting you about all sorts of things. To find the right balance, we will only use your information:

  • To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
  • To offer services to you or to obtain support and services from you;
  • To perform certain legal obligations;
  • To help us to target appropriate marketing campaigns; and
  • In more unusual circumstances, to help us to establish, exercise or defend legal claims.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address. If you are not happy about this, in certain circumstances you have the right to object.

REFEREES WHOSE DATA WE RECEIVE FROM CANDIDATES:

In order to provide Candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our Staff, we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you for a reference. We collect your contact details only where a Candidate gives them to us in order for you to serve as a referee.

How do we use your personal data?

We use referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them.

Who do we share your personal data with?

Unless you specify otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.

What kind of personal information do we collect?

 All we need from referees is confirmation of what you already know about our Candidate or prospective member of Staff, so that they can secure a job. To ask for a reference, we’ll obviously need the referee’s contact details (such as name, email address and telephone number).

How do we use your personal data?

We will only use the information that our Candidate gives us about you for the following purposes:

  • If you were put down by our Candidate or a prospective member of Staff as a referee, we will contact you in order to take up a reference. This is an important part of our Candidate quality assurance process, and could be the difference between the individual getting a job or not.
  • If you were put down by our Candidate or a prospective member of Staff as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you are not happy about this, you have the right to object.

WEBSITE USERS:

We collect the following information relating to our website visitors automatically: domain name, IP address, and type of browser used and type of operating system used. We use this information for internal statistical analysis, such as to see where our website is being used geographically.

However, we do not link this information with any personal data.

GENERAL OVERVIEW: SPECTRUM’S USAGE OF PERSONAL DATA

Who else do we share your personal data with?

Where appropriate and in accordance with local laws and requirements, we may also share your personal data, in various ways and for various reasons, with the following categories of people:

  • Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
  • Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
  • Marketing technology platforms and suppliers;
  • If Spectrum merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

How do we safeguard your personal data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately by sending an email to response@spectrum-ehcs.com .

How long do we keep your personal data for?

We will Delete your personal data from our systems if we have not had any meaningful contact with you for some time as it is likely your data will no longer be relevant for the purposes for which it was collected.

When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate we will consider there to be meaningful contact with you if you submit your updated CV to us. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

How can you access, amend or take back the personal data that you have given to us?

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 that you retain various rights in respect of your data, even once you have given it to us.

To get in touch about these rights, please contact us at response@spectrum-ehcs.com . We will seek to deal with your request without undue delay, and in any event within 30 days (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object:

This right enables you to object to us processing your personal data where we do so for one of the following four reasons:

  • our legitimate interests;
  • to enable us to perform a task in the public interest or exercise official authority;
  • to send you direct marketing materials; and
  • for scientific, historical, research, or statistical purposes.

The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Candidates, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:

  • we can show that we have compelling legitimate grounds for processing which overrides your interests; or
  • we are processing your data for the establishment, exercise or defence of a legal claim.

If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

Right to withdraw consent:

Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

Data Subject Access Requests (DSAR):

You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

Right to erasure:

You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:

  • the data are no longer necessary for the purpose for which we originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
  • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for one of the following reasons:

  • to exercise the right of freedom of expression and information;
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
  • for public health reasons in the public interest;
  • for archival, research or statistical purposes; or
  • to exercise or defend a legal claim.

When complying with a valid request for the erasure of data we will take all reasonably practicable steps to Delete the relevant data.

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 activities with it until either:

  • one of the circumstances listed below is resolved;
  • you consent; or
  • further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

  • where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
  • where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
  • where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
  • where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

Right to rectification:

You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right of data portability:

If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your details. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected. Alternatively, we may directly transfer the data for you. This right of data portability applies to:

  • personal data that we process automatically (i.e. without any human intervention);
  • personal data provided by you; and
  • personal data that we process based on your consent or in order to fulfil a contract.

Right to lodge a complaint with a supervisory authority:

You also have the right to lodge a complaint with your local supervisory authority.

If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us by email at response@spectrum-ehcs.com .  You may withdraw your consent to receive marketing communications only or all consent to receiving any communication from Spectrum.

Please note that we may keep a record of your communications to help us resolve any issues which you raise.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

OUR LEGAL BASES FOR PROCESSING YOUR DATA
  • LEGITIMATE INTERESTS

Article 6(1)(f) of the GDPR says that we can process your data where 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 interests or fundamental rights or freedoms of [you] which require protection of personal data.”

You have the right to object to us processing your personal data on this basis.

CANDIDATE DATA:

If you make us aware you are looking for employment or have posted your professional CV information on a job board or professional networking site, we think it is reasonable to assume that you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our vacancies.

Once a candidate has been shortlisted for a job, the prospective employer may also want to double check any information you’ve given us (such as the results from BIP tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws.

We want to provide you with tailored job recommendations and relevant articles to help you on your job hunt. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content. We may also invite you to our networking events as part of the service we offer to you.

We may also ask you to undertake a post mandate feedback survey to gain valuable insight into our key performance indicators as a business.

We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.

NOTE – We will never share your details with any 3rd parties, without your permission. If you have sent us a CV, it will never be submitted to a client without your approval.

CLIENT DATA:

To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. We may also ask you to undertake a post mandate feedback survey to gain valuable insight into our key performance indicators as a business.

We think this is reasonable use of your data for our legitimate interests as an organisation providing various recruitment services to you.

NOTE – We will never share your details with any 3rd parties, without your permission.

SUPPLIER DATA:

We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.

REFEREES WHOSE DATA WE RECEIVE FROM CANDIDATES:

If you have been put down by a Candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.

  • CONSENT

In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.

Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” This means that:

  • you have to give us your consent freely, without us putting you under any type of pressure;
  • you have to know what you are consenting to – so we’ll make sure we give you enough information;
  • you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
  • you need to take positive and affirmative action in giving us your consent.

We will keep records of the consents that you have given in this way.

We will be able to rely on soft opt-in consent to market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications.

You have the right to withdraw your consent to these activities. You can do so at any time, by sending an email with your details to response@spectrum-ehcs.com .

  • ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

Sometimes 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”.

This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

SPECTRUM’S DATA PROCESSORS

Spectrum is the “data controller” and uses the following “data processors” to support our business. Spectrum is committed to ensuring all our suppliers are fully GDPR compliant. Please refer to their individual Data Protection Policies:

Invenias  – https://www.invenias.com/about/privacy/

Concep  –  https://www.concep.com/privacy-policy/

Cloud Direct  –  https://www.clouddirect.net/legal/privacy-policy/

 

 

Updated April 2018