Please use the links below to help you find what you are looking for more easily
This explains who we are and our commitment to using your data as you would wish
Who we are and what we do
This explains why we might need to record your personal information
Go here for a quick summary of the General Data Protection Regulations
What information might we collect about you?
Go here if you want to know more about the information we hold
Other uses of your data
Head here to find out potential alternative uses for your personal data
Who we may share your information with
Check here to see who else we might share your data with
Where we store and process your personal data
This section explains how we keep, process and protect your data from misuse
Retention of your data
This section explains how long we keep your data for and why
For the purposes of data protection legislation, the data controller is Trinity Scott of 37 Marlowes, Hemel Hempstead, Herts, HP1 1LD.
Trinity Scott (”We”) is committed to protecting and respecting your privacy.
We are committed to protecting the privacy of our candidates, clients and users of our website. We want to provide a safe and secure service where we deal with your personal information. This means information that identifies you personally such as your name, photo or contact details or data that can be linked with such information in order to identify you.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group). Trinity Scott is part of the ALC group of companies, comprising currently ALC Executive and ALC Discovery.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
WHO WE ARE AND WHAT WE DO:
We are a careers advice service, recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We also provide the following other services: sector information, salary benchmarking, training, consultancy. 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;
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) 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.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
WHAT INFORMATION MIGHT WE COLLECT ABOUT YOU?
We collect information about you to carry out our core business and ancillary activities.
This is information about you that you give us by accepting a LinkedIn connection request from one of our staff, or by corresponding with us by phone, e-mail or online. It includes information you provide when you subscribe to our services, attend our events, or occasionally participate in online discussions or other social media functions connected to our company.
The information you give us, or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website. It also may include notes taken from conversations with you, and any information contained within email messages between us.
Types of information we may collect about you
This is information we primarily obtain about you from LinkedIn and other publicly available sources. It consists of your full name, job title, company, length of time in the industry, and LinkedIn url. We will not inform you if we hold this low-level information as it is already in the public domain.
Contact (“Basic Plus”) information
This is information we obtain about you from a LinkedIn level 1 connection with each other, or from sources such as corporate websites, job board websites, online CV libraries, your business card, and personal recommendations. It consists of the above basic information but in addition will include contact details such as a telephone number and email address.
In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data, of the fact we hold personal data about you, exactly what it consists of, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process this data.
When we are considering you for either a specific current role, or for potential future roles, we may also collect the following information from you: a CV, notes from a conversation, salary details. When we are in the process of placing you in a role, we may also request proof of qualifications, passport and visa information, payroll details and other more sensitive information. We may also request references about you.
We will always obtain your consent for holding this additional information and be specific about where it will be used. We will not request references about you without your express prior permission.
We may sometimes collect more sensitive information about you, such as bank details or details of criminal convictions.
We will always obtain your prior consent for holding this information and be specific about where and how it will be used.
We are working closely with other companies in our group. We may pass information about you to them for the purposes of their and our recruitment services and ancillary support services. This information will remain confidential within our group of companies and will not be passed on to any third party without your express prior permission.
PURPOSES OF PROCESSING AND THE LEGAL BASIS FOR PROCESSING:
Summary table of our legal basis for processing data
|Type of data||Content example||Legal basis|
|Basic Information||Full name, job title, company, length of career, url.||Publicly available – data subject not usually informed|
|Contact Information||Email, mobile number, occasionally address.||Legitimate Interest – will notify data subject within 30 days|
|Additional Information||CV, notes from a conversation, salary details.||Consent – we will request this from you when we obtain the data|
|Messages & communications||Usually information provided by the data subject themselves about their situation (eg via email)||We will assume that by providing us with this data, the subject is happy that we have it. No need to inform subject.|
|Opinions from recommendations/
|The best worker in a team, or who is unhappy and might wish to move roles||Legitimate interest – this information is part of our core work. We will not request permission to hold this as that would negate its nature, but we will reveal it as part of a SAR.|
|Sensitive Information||Criminal convictions, bank details||Consent – we will request this from you when we obtain the data.|
|Introduction||Introducing a candidate to a client||Consent – we will request this from you before we make the introduction|
|Placement Agreement||Contract agreeing your placement at a firm||Contract|
|Legal Obligation||Obliged to disclose information for legal reason||Legal Obligation|
We use information held about you in the following ways:
- The core service we offer to our candidates and clients is the provision of careers advice and support, mainly to individuals involved in a research function within an executive search or recruitment capacity.
- We also enable the introduction of candidates to our clients for the purpose of temporary or permanent engagement.
- Our service also expands to supporting businesses’ resourcing needs and strategies.
- Moreover, we may decide to provide you with information, products and services that you request from us or we think will be of interest to you because they are relevant to your career or to your organisation.
- We may also provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
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.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
As outlined above, 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:
- Holding data about you above and beyond basic contact information (eg a CV, notes from a call, other higher risk personal details such as salary information)
- Asking permission to introduce you to a client (if you are a candidate).
DATA USE FOR LEGITIMATE BUSINESS INTERESTS:
As a careers advisory service 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 candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
We also need to keep a record of any recommendations, intelligence or inside information about potential candidates. Due to the nature of this information, we will not obtain consent to hold it, as this would negate its purpose, but it must be noted that we do not treat it as necessarily factually accurate. We will also reveal all information of this nature as part of a Subject Access Request.
The above represents our legitimate interest in collecting and retaining your data.
DATA USE REQUIRING CONSENT:
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.
If you withdraw your consent
If you do not provide the personal information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide recruitment services to you, we may not be able to match you with available job opportunities.
OTHER USES WE MAY MAKE OF YOUR DATA:
- to determine what information, we provide on our website;
- to notify you about changes to our service;
- to inform you of forthcoming events that may be of interest to you (if you have signed into this service).
We will use this information:
- to administer our website, supply our services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our service to ensure that our offer 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 (eg surveys).
- as part of our efforts to keep our website safe and secure;
- to make suggestions and recommendations to you and other users of our services about goods or services that may interest you or them.
We do/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.
WHERE WE STORE AND PROCESS YOUR PERSONAL DATA:
If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.
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. Trinity Scott will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. 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 run data routines to remove data that we no longer have a legitimate business interest in maintaining.
Length of data retention
We will keep your data for 2 years. After this time, we will either delete it, or contact you to inform you under legitimate interest that we are continuing to hold it. We will retain the information if it is still accurate and relevant. If the data is more detailed than basic contact information, then we will contact you to request your consent to continue to hold it.
We do the following to try to ensure our data is accurate:
Our CRM (Customer Relationship Manager) system alerts us after your data is held for 2 years to perform a check as to whether it is still accurate. This check is performed by a person, not automatically, using online sources or by contacting you directly.
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 CRM. 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.
You have the right to ask us not to process your personal data for marketing purposes. We will usually 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 contacting us at email@example.com.
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 they have their own privacy policies and that we do not accept any responsibility or liability for these. 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). This is also known as “the right to be forgotten”.
- Object to processing (withdraw consent) 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.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
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.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force.
A subject access request should be submitted to firstname.lastname@example.org.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
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.